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Pleadings

Complaints

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CA – Complaint for Negligence and Jury Demand

SC – Summons and Complaint Wreck Case – Negligence

NC – Personal Injury Complaint

Appeals

Federal

Appellate Brief – Federal

Petition for Hearing En Banc

State

2255 Motion to Vacate Sentence

Civil Appeallate Brief (family)

Immigration Appeal

Immigration Appeal

Research Memos

Formal Memos

DC Record Retention Schedule

Michigan Attorney Discipline Board

Research Memo on Alston Case – Tax issue

Informal Memos
Criminal Restitution and Bar on Civil Action for Personal Injury

Pre Trial

Discovery

CA Request for Production

Request For Admision CA

Discovery CA Special Interrogatories

Discovery Requests -Interrogatories MI

Requests-for-Production MI

Petition for Post-Conviction Relief

Petiton for Post Conviction Relief
Petition for Post Conviction Relief AZ

Criminal

State

Motion to Vacate Plea Agreement

Probation Violation Appeal

Motions (Civil)

Motions (Civil)

NY – Memorandum in Support of Motion to Vacate Default Judgment

MI – Motion to stay enforcement of judgment of divorce

NC – Brief in Support of Motion for Summary Judgment

Response

Response

Response to Cross Motion for Summary Judgment

Response to Motion for Summary Judgment – MD

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