I need a Motion to Continue Trial Date and an Ex Parte Motion to Shorten Time on Hearing on Motion to Continue Trial Date.
My case is set for trial on 3/11 with a pre-trial conference on 2/26 at 10:00 am. My client is in California and cannot travel to Hawaii for trial because of a medical issue (knee replacement, not cleared yet to travel). I have the note from the doctor.
I need the Motion to Continue to be heard on 2/26 at 10:00 am. I need an Ex Parte Motion to Shorten Time asking that the Motion above be set for hearing at the pre-trial conference. I expect this to take 3 hours. This is the second time I’ve had to file a Motion to Continue with an Ex Parte so I have Word docs that just need updating and amending.
What a feeling to come into the office on Monday morning to be greeted by two solid work products! Robert did a great job with very little information on a tight time-frame (gave project Friday, received Monday am). Robert took the samples I gave him plus the relatively sparse facts that I had time to share on a Friday afternoon and wrote a Motion and Ex Parte Motion, both of which are 90% ready to go, except for some beefing up of the history and the most recent facts. Robert was responsive, friendly, competent and professional.
Need to add information to Amended Motion regarding Appeal of Default Judgments.
Petitioner Father received a significant downward modification of child support that was possibly not supported by the law. It was from an order that was obtained through a default judgment.
Initially, I was concerned about the quality of work that I would receive and the ease that I would have with communicating with the attorney assigned to the project. My experience was absolutely wonderful. Issues that I had not spotted prior to making the assignment were identified and researched in favor of my client. It was clear that Chris really cared about the case and wanted us to be successful for the client. I really felt like I had a teammate. I will use Chris again.
I need someone to finalize interrogatory requests and include objections. I will upload responses to the Request for Production so you can see what my objections generally are. Basically same type of objections.
Parties have been separated since 2016. They separated all of their assets at that time except for retirement accounts that required a QDRO. Wife hired an attorney who is being difficult, to say the least. He sent out discovery on issues that are completely irrelevant given the parties’ date of separation. In addition, pursuant to Kansas Supreme Court Rule 135, he is limited to 35 interrogatories and he greatly exceeds that number. I will upload the request for production I served on him so you can see the general objections. I will also upload the client’s responses.
Colleen worked very hard, was very responsive and turned out a wonderful work product! Thrilled, and will be hiring her again. Thanks, Colleen!
I need assistance drafting an Amended Brief for New Trial. The trial transcript needs to be reviewed and the appropriate facts from the trial included in the Amended Brief for New Trial. The trial was less than a couple of hours as it only involved child support.
The amount my client receives in child support was significantly reduced because of her attorney’s failure to adequately represent her interest. He failed to even complete a child support worksheet to present at trial. I believe she has a strong claim for ineffective assistance of counsel.
Mike did an excellent job. He found issues that I had not considered but worked in favor of our client. I would definitely work with him again.
This is an appeal to the 3rd DCA on a family law matter involving procedural issues and recognition of a foreign divorce decree.
A short summary. 1. Wife files for Divorce and her attorney files a poorly drafted Petition and fails to request unequal distribution or any sort of alimony. 2. Husband files a Motion to Dismiss alleging that the parties were divorced in Panama by Proxy 3 years prior and does not answer the Petition. 3. Wife files a motion to set aside or vacate the Panama divorce decree. 4. The Court holds a hearing and hears both motions at the same time and takes evidence on the issues. The Court finds that the Wife had no due process, no disclosure, and that neither party ever resided in Panama or has any ties to Panama. The Court denies the Motion to dismiss but does not set aside the whole Panama judgment and retains jurisdiction over equitable jurisdiction and alimony. The Court does not order the Husband to answer the Petition and he never answers the Petition. 5. The Husband/Respondent files a trial notice without answering the Petition and the Court enters a trial order. 6. The trial gets continued several times on joint motions until both parties’ counsel withdraw in December 2018. The Court enters a trial order for February 2019. 7. The Wife does not appear at the trial and the Court awards everything to the Husband because she does not appear. 7. I come into the picture and file the motion for rehearing. 8. My paralegal quits and does not calendar the hearing on the rehearing and I do not show up but my client shows up and the Court only hears from the Husband’s attorney and summarily denies the motion. 9. I file the motion to vacate the judgment and the Order on the Motion for Rehearing and the Notice of Appeal.
This project should take 10 hours.
Excellent writer and she delivered prior to the deadline.
This project is for a Prenuptial Agreement under Pennsylvania law. The parties’ biggest concern they want to address is expected death of Husband and kids from a prior marriage and treatment of Wife’s substantial assets.
There are some estate planning considerations as the parties have moved up a wedding date due to Husband’s recent terminal cancer diagnosis. Wife is client -- she has substantial assets on her own (real estate, retirement accounts, etc). Husband is disabled and retired and has very modest assets (car & house owned jointly with Wife, not much else of his own). Financial Statements have already been prepared by the parties and copies will be provided to the Lawclerk to use as needed in the Agreement.
Timely, good communication, and good work product!
I need a motion to modify a joint physical custody schedule, clarify a vacation provision, and have a telephone contact schedule for the non-custodial parent.
Parties very recently agreed to joint physical custody with a week on week off time share for a 5 year old child. Dad agreed to the schedule under the guise that if it wasn’t working they would revisit it. Mom is not allowing frequent contact with the child when he is with her, and Dad’s work is threatening to fire him because he is showing up late and leaving early on his weeks. Dad thinks it would be better for the child to have a schedule of Monday-Tuesday with Dad, Wed-Thursday with Mom, and then alternate Fridays-Sundays.
They also have a vague vacation agreement where it says that they both have to agree to any out of town travel, but that if they can’t agree, they can go anyway.
Tara wrote a great motion to modify custody that was complete on the first draft submitted. She made great arguments without much direction, and was mindful of the deadlines. I would absolutely use her again.
I need a Motion to Dismiss a Petition for Adoption that shall incorporate relevant case law and statutes for the court to review in support of the motion. This can be done in one document or a simple motion with a supporting brief. My OC has filed this petition and represented to the court that a court order was final when it was not, and used it to support her petition for adoption. There are some ethical issues at play here too. I am asking for the dismissal as a sanction for the misrepresentation and because there are other matters that are pending that must, per statute, be dealt with first.
The finished document will probably be 5-6 pages, but could be longer due to the relevant statues that are at play and the need to include them for the convenience of the court. It will take about the same number of hours to complete. I have done some of the research and I am happy to provide what I have.
Kingsley was very easy to work with and made adjustments and edits when asked. He worked well independently and made notes where he felt I might want to include additional facts. I am very pleased with the result and would use him again.
I just need a first draft of a Motion to Modify Temporary Order.
Preferably someone who has drafted one before or can pull a good sample and work from that. I just need help with good, relevant and recent case law.
Excellent, excellent! Taylor was very responsive and very quick. Thank you for a great job! I would definitely recommend him.
I need a trial brief memorandum dealing with family law dissolution issues of a parenting plan (with abuse elements), division of assets/debts, division of property, and child support calculations. I have the calculations, proposed final orders, and information needed. I am looking for someone to compile all the information into the brief for trial.
I anticipate about 4 hours of work. I will provide the basic case law, fact information, and client documents to get you working quickly. There will need to be a little bit of case law research on entering cps and police records at trial for a family law case and the implications of hearsay. The brief is pretty straight forward.
Alicia did a very good job. She reviewed the pleadings to make sure she covered all of the issues in the case; her writing was clear and concise. I asked her to conduct some research into an issue and she did a good job on her research.
Memorandum of law in support of change in custody. Brief will argue that relocation standards do not apply to request to change custody of child back to parent who is not moving (though parent lives four hours from custodial parent).
Expected length is 8 pages.
I will provide case law of approximately 50 pages to review and the brief of the other counsel.
She did a nice job on a tight deadline.
I need a Final Order drafted denying the Motion on Contempt. This is only the Order not a brief on anything.
Parties came before the court.
Provide proposed order denying the Motion for Contempt.
We just want our client to pay the arrears over time. Thanks.
Great experience and such a great draft under the time restraints that we gave. Thanks again!
Motion for Sanctions
There are 43 distinct requests; we are objecting to several.
All documents are scanned and digital.
1. Review supplied docs (they are separated into folders!)
2. Compile docs into one PDF file
3. Bates stamp the docs
4. List the Bates numbers on the RFP response/answer document
You will need a dropbox account and some type of software that can compile docs into an Adobe-recognizable PDF file.
Good work answering a RFP in a family matter involving 1400+ pages of documents. Recommended and will hire again.
I need a memorandum detailing what information I should seek in the deposition of the respondent father in a Termination of Parental Rights case in order to put me in the best position to later prevail on a Summary Judgment Motion filed on behalf of my client, the petitioner mother.
My client is a mother who has filed a Termination of Parental Rights Petition requesting the termination of the parental rights of her child’s biological father. The 2 grounds we are alleging are abandonment and failure to assume parental responsibility. I will provide a summary and documentation to illustrate the fact pattern. I am planning to take the deposition of the father in an attempt to create a record that will support the filing of a Motion for Summary Judgment on the issue of abandonment and/or failure to assume parental responsibility. I will need research on the law and an examination of the facts established so far so as to provide me with a memorandum detailing what further facts I will need to illicit to create a record that will allow me to prevail at the Summary Judgment Motion hearing.
Ty researched issues and provided a clear and concise memo addressing the items requested. Hope to work with Ty again. Thank you!
The parties are to attend mediation for resolving both property division and spousal support.
We represent Husband. I will be able to provide a spreadsheet setting out the assets and debts claimed by the Wife where Husband has the resources. I will provide access to a dropbox file with documents and info. There is a guideline formula for spousal support. You will have that in a spreadsheet calculator. The goal would be to produce a spreadsheet stating our position and a memo to the same intent. You will have access to a file to pull any documents you may want for supporting exhibits via a dropbox link.
Amanda was good to work with and provided a preliminary version to make sure she was on track. It was a time saver. Material turned in before the deadline.
Interogs in a child custody/support case.
I’ve tried to make this as streamline as possible. This is an interrogatories and request for production of documents in a Tennessee Child Support case. Here are the steps:
1. You’ll open the Microsoft word document entitled “template.”
2. Many attorneys send you a template that actually isn’t the official copy they mailed! So the document entitled “mail” is the actually copy received. Please use this as a reference if something doesn’t make sense. The “template” should match the “mailed” version at the end.
3. You will plug in the information in “Client’s unedited answers” into the “template.”
4. Clients value their time over the wisdom of attorneys so you will take some liberties with their words to make them succinct and professional. If the answer is incomplete (in your opinion) just write what’s missing in red. Please keep in mind you are simply doing a first draft for me and I will be meeting with the client in person to review this version, add or take away info, and they will be signing the version they are comfortable with!
5. The folder entitled “documents” has the documents meant to correspond with the Request for Production of Documents in the “Template.” Please organize these, list any deficiencies in red on your draft, and label the appropriate documents by what request they reference and what the documents are . Ex. “ RDP-1 Bank Statements”
Sometimes a subsection will ask for things like “bank statements and credit card statements.” Please make 2 PDF’s for each item. Ex RDP-1 Bank Statements ; RDP 1 Credit Card Statements. Put these all in a folder named “RDP 1.”
6. Additionally, I have a folder titled “pleadings.” This Folder is not needed for the answers but you may need them for context. It’s probably a good idea to scan them for about fifteen minutes before you get started.
Excellent work. He noticed a few things that I didn’t. He’s always my first choice on projects.
ND - Step Parent Adoption Pleadings (with ICWA consideration)
I need a RUSH completion of Step Parent Adoption Pleadings. Must be based on applicable ND law and incorporate ICWA. Person chosen will receive all of the applicable legal research and basic forms for completion, along with client information to complete documents.
Docs to be completed:
Service Documents
Petition
Affidavits
Notice of Hearing
Amber’s knowledge base when it came to an ICWA issue in a family law matter exceeded my expectations. She was spectacular in drafting the initial pleadings I needed done. She completed them ahead of schedule and had no complaints when I needed some formatting revisions. I would absolutely hire her again for any project.
I need a bill of review application and brief supporting it, applying the Texas standards for setting aside a default divorce judgment.
In this case, my client had a default judgment entered against him. The judgment basically awarded the entire community estate to the wife. He works out of town and did not know about the final hearing, so did not attend. He hired an attorney for a motion for new trial. At the hearing, they talked about the wrong standard for the time (was he served properly?) as opposed to the correct standard (did he act indifferently?) and the judge denied the MNT.
Because of timeline issues, we don’t have the ability to file for any relief other than by Bill of Review. There are allegations from the MNT hearing that the other party purposely tried to hide the notice from my client. Because she acted purposefully to harm my client and he did not act indifferently, we should be able to make a credible Bill of Review argument.
I need a brief that clearly lays out the standard of the Bill of Review in Texas, particularly in divorces, and applies the facts of this case to that standard. I would also like to include examples of divorce cases in Texas in which the court applied the Bill of Review standard to default judgments. We really don’t like defaults in Texas so hoping that will influence things.
I expect a simple Bill of Review application and a brief of two to three pages in length. This should take less than 5 hours.
This brief will need to be written in a way that a human being who’s disinclined to reopen a case can understand it. Conversational, but direct; brief, but thorough.
In short, please don’t write like a lawyer, but write so a lawyer can understand you and feel like all the boxes were checked. That’s threading a needle, I know.
Rob is such a strong writer. He’s direct and clear, making it easy for a judge to understand what my client wants and the reasons he should get it. Rob also responded quickly to messages and provided plenty of legal authority for my client’s position. I’m very, very impressed.
Supporting materials for a speaking engagement regarding Child Support and UIFSA.
I need some written materials prepared to support a speaking engagement. I’m looking for a case survey regarding UIFSA cases in Tennessee; an update on any new child support laws in Tennessee; I’m particularly interested in cases where our Court of Appeals has reversed the trial court during the past year; I would like a discussion about defining income to address how the courts should deal with 2nd jobs, overtime, SSDI, VA benefits in the computation of gross income according to our Tennessee Child Support Guidelines; the proper process for dealing with imputing income to a voluntarily under employed party; and the proper process for modifying child support.
Erin did a great job. I would certainly look to her for help on a project in the future.
I am seeking a Trial Brief and a Settlement Conference Brief for the same case addressing issues including modification of a parenting plan, restrictions on a parenting plan, a final parenting plan (custody), and restraining order.
This is a military family law case. I would appreciate someone familiar with military language and child protective services. The Trial Brief and Settlement Conference Brief are pretty similar and include a lot of the same information. This is why I am putting them together for the assignment. I anticipate the two documents will be about 7 hours of work. I would like an approximate 8-10 page document (for both) that covers (at a minimum): The facts: the parties, the history of the parties, the children of the action, brief history of litigation, CPS history, and the issues with the current parenting plan. The issues: include whether the court should modify the current parenting plan, whether the court should place restrictions on the mother or father, a final parenting plan (custody), and whether the court should grant a restraining order. I would expect legal research on each point and why the court should accept our proposed final documents. I have already drafted all proposed final orders and I will supply you with Washington case law quick cites to get you started on the legal research.
Jordan definitely goes above and beyond on her work!
I need solid research and a 2 page memo detailing Pennsylvania law regarding vacating or opening divorce agreements due to alleged fraud and how it applies to the facts of this specific case. Parties entered into a marital settlement agreement on the record - one party indicated that the loan for the premarital residence was in his/her name alone - the other party agreed to pay $$ to settle. The $$ to be paid within 90 days - and once the $$ paid - the decree would be entered. Party who is to pay $$ - learned that his/her name is associated with the loan - and that his/her name was signed to loan documents post-separation. S/he relied on the representation that her/his name was not associated with any loans. S/he is now not able to obtain financing to pay $$.
Perform legal research and write a no more than 2 page memo on a very narrow issue. It would be expected that the research, an analysis, and writing will take no more than 4 to 5 hours. Becomes a bit complicated because decree not issued - fraud issue - extrinsic/intrinsic?
Not only did the Lawclerk find good legal precedent - he called me and helped me with looking at both sides of the case. Carrington went way above to make certain that I had what I needed but also that he understood and I understood the law and application to my case. I look forward to working with him again.
I need CPS and family court documents reviewed and questions formulated for direct examinations of witnesses in a child placement case with the documents marked up identifying relevant portions for refreshing witness’ recollections if needed. I also have the client’s addiction/mental health records for review and mark up for trial, as well as some text messages between the client and the father that need to be reviewed and marked.
Please also summarize the discovery from CPS for me in a memo.
I represent Mom in a child placement case. There is a family case between the parents and now a child protection case as well. There are documents in both matters, and I am preparing for the hearing at which the court will determine the placement schedule between the parents. I will provide the documents in both cases, the parenting plans and witness lists filed by both parents, and the transcript of my client’s deposition. I will provide all the records I am asking to be reviewed.
OUTSTANDING!!
I need a proposed consent order clarifying the final judgment in Florida family court. The prior divorce attorney did not properly address the 401k split in the marital settlement agreement, therefore a QDRO cannot be drafted and the 401k cannot be split. This should take no more than two hours.
This should be a short, relatively simple project for someone who deals with family law or who has dealt with clarifying an issue before.
Crystal is very pleasant to deal with and did a good job on my project. She needed some direction after the draft and it was taken and applied very well. She was timely and easily accessible. I would use her again.
I need a response drafted for this Motion to Enforce a custody order. A lot of allegations are thrown about and the AP’s counsel wants attorney's fees. We had a hearing in a related DV matter today and the judge did not accept the photos AP supplied to support their theory that the minor child was hurt by a trampoline accident. The AP father also admitted seeing the injuries to the child’s arm which were shown in photos taken at the medical center. Basically, we have updates to the allegations and theories raised in this motion and a response is needed to deny the motion.
Project time is estimated to be about 3 to 4 hrs. The number of pages is between 6 to 10. The discovery needed can be supplied in a later project, but if there are recommendations please supply those and we can setup another project for the discovery.
Comprehensive and communicates often. Well done.
Motion in Limine to admit the prior testimony of a Physician that already testified at a preliminary hearing and to bar the other side from mentioning any DCFS complaints (unfounded returns).
We filed a petition for preliminary injunction. We swore a physician in and had his testimony. The other side was represented by counsel and had the opportunity to cross-examine the witness. The other side miraculously agreed to an agreed order after the doctor testified to bad facts for the other side. They didn’t follow through. Now we are basically going to try to re-file the same petitions or head to final hearing. We do not want to have to subpoena the doctor to testify again. It is a recorded courtroom and the testimony will be available (and likely attached to the motion). We want to file a motion in limine to get the court to admit the testimony as evidence in any future hearings/trials.
Next, we want to file a motion in limine to bar the individual from telling the judge at any time that my client has filed any DCFS complaints against him that have returned unfounded. I do not believe the other side can just tell the judge that my client is filing DCFS complaints against him.
Very good work.
I need a memorandum addressing the following questions:
1. Who pays the tax on a Wisconsin family support order? The payor or the payee?
2. If my client is awarded a portion of her spouse’s 401(k) and she chooses to cash out that award, are there steps she can take to avoid paying the tax and/or the early withdrawal penalty?
I am being told that the answers I have understood to be correct in the past on these issues may be changing in 2019 due to some new laws in this regard, so I want to have correct/updated information regarding these issues.
Matthew prepared a research memo for us clearly answering the questions we had. He also quickly answered follow up issues we raised. I would highly recommend him.
This is on a previous case you worked on. You did a motion to exclude the Doctor’s testimony. I have the other side’s response. The hearing is tomorrow morning, and I would like you to put together some arguments for me. I realize this is very short notice, so I cannot be flexible on the deadline.
See project description.
Great product on very short emergency deadline. Thank you Charles. Look forward to many more projects with you.
Opposing party has filed a petition to modify a divorce that is in our opinion past any reasonable time. Seeks to modify the allocation of retirement income several years later.
Need a motion, memorandum and affidavit in support of a motion to dismiss. Client relied upon the agreement and original divorce to move out of Utah and retire from Utah sooner than he would have if he had to share his pension income. The parties were both unrepresented in the original divorce matter. She claims he mislead her about the nature of her rights to part of his pension.
Timely and very well done. Helped clarify project and scope.
I need a memorandum that briefly summarizes the case law regarding sufficient reasons to restrict a JMC’s possession and access to supervised.
I’m anticipating a 1-2 page memo with case examples of sufficient cause to restrict visitation to supervised possession only rather than a standard possession order in the absence of domestic violence or drug abuse. I’d like to know whether the recommendation in a custodial evaluation for supervised access alone is sufficient. I estimate maybe 2-3 hours to get this research project done. Assume the custody evaluator determined the parent sought to be restricted exhibited Munchhausen’s by Proxy behaviors toward the children and spouse and Munchhausen’s behaviors for self.
Thorough research on exactly the issue I needed.
I need my client’s preliminary financial disclosure statement prepared.
I will provide a skeleton document to be used and the completed FDS worksheet I asked her to complete along with the supporting documents she provided.
Consistently great work.
I need a 1200-1500 word article explaining the Virginia equitable distribution process in plain language to a lay audience, including classification of property, valuation of property and how property may be valued (for instance an appraisal/appraiser for real estate).
You must be an experienced Virginia family law attorney.
Please discuss how the presumption legally is not equal, but many judges “default” to this.
Discuss how debts are divided.
Discuss what happens after the hearing - deeds may need to be signed or payments made.
Discuss how this most often happens a year or so after divorce is filed and pendente lite hearing has happened, as well as discovery.
He did a great job.
I need a memorandum regarding my client’s income and what the appropriate income is to use as “gross income available for child support” under Wis. Stats.
My client is a W-2 employee. His gross income as indicated on his last paystub for 2017 is different than what is indicated on his 2017 W-2, and I do not know why this is. I would request that you review his 2017 income tax information and a sampling of his 2017 and 2018 pay statements and determine why there is this discrepancy (I suspect it may be due to a cafeteria plan his employer may offer or due to his 401k contributions), and determine what an appropriate income figure is to use under Wisconsin Statutes and the Wisconsin child support guidelines when determining his child support obligation for 2017 and 2018.
Matthew did everything we were looking for and went beyond. Extremely helpful in answering our specific follow up questions. Clearly very knowledgeable.
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