Civil Litigation

Temporary Restraining Orders (TRO) / Permanent Protective Orders (PPO): Experienced representation of plaintiffs and defendants in domestic violence and non-domestic violence permanent protective order hearings before county court magistrates and judges, motions to dismiss and modify protective orders, motions to dismiss existing protection orders, burden of proof and required evidentiary findings of magistrate or judge in determining whether permanent protective order appropriate, petition for review of issuance of protection order by district court, filing deadlines and time requirements for defendants, effect of protection orders on the restrained party’s rights, rights of restrained parent as to common children of parent-litigants.

Divorce / Domestic Relations / Family Law: Experienced as counsel for petitioners and respondents litigating divorces, legal separations, and the allocation of parental rights and responsibilities, including compliance with mandatory discovery of financial information, additional discovery, requests for documents, depositions, mediation, and status conferences, and litigating temporary orders hearings and final orders hearings, hearings on custody / parenting time, and allocation of parental rights and responsibilities in the best interests of the child / children, child support, award of spousal maintenance / alimony, temporary and permanent maintenance / alimony / spousal support, Petition for Allocation of Parental Responsibility, Petitions to Determine Parentage, common-law marriage, negotiating marital property settlements including fair and equitable division of marital property, property including martial home, military retired pay and spousal benefit insurance (SBI) for soldiers and their spouses, drafting settlement agreements, parenting plans, and temporary and final orders for the court, as well as pre-nuptial agreements. Post Decree Litigation including Motions to Modify Parenting Time, modification of parental responsibilities and decision making responsibilities, motions to enforce parenting time, motion to relocate out-of-state with minor child, motion to modify child support, motion to modify maintenance / alimony, retroactive support, arrearages / past-due support obligations, motion to enforce parenting time, emergency motion to restrict parenting time on grounds of imminent physical or psychological harm to child, motions for contempt, contempt citations and contempt hearings, and punitive and remedial contempt sanctions, collection of child support in arrears via wage assignment / writ of garnishment, working with Child Support Enforcement (CSE).

Juvenile Law: Experience representing parents and children in juvenile cases including delinquency proceedings and dependency and neglect proceedings, negotiating with the district and county attorneys, case workers and case managers from the Department of Human Services (DHS), working with Office of the Guardian Ad Litem (GAL), working out family services treatment plans, negotiating and arguing for temporary and permanent placement of minor child, determination of legal and physical custody between parents, relatives, and state, juvenile criminal adjudications, juvenile felony and misdemeanor convictions, minor in possession of alcohol (MIP), juvenile offender tracking program, alternatives to Department of Youth Corrections (DYC).

Landlord-Tenant: Experienced prosecuting and defending forcible entry and detainer actions (FED), reviewing and construing leases, negotiating with landlords and property managers, obtaining writs of restitution for sheriff-assist in eviction, rights of landlords and tenants, constructive eviction, implied warranty of habitability, covenant of quiet enjoyment, money damages for destruction of rental property, punitive money damages for unauthorized retention of security deposit.

Commercial Litigation: Experience representing defendant-contractors and vendors in breach of contract claims by homeowners and consumers, contactor’s opportunity to remedy defective work, the workmanlike standard for improvements to real property, contracts for the sales of good in Colorado, compliance with Federal Trade Commission (FTC) requirements for vendors, claims brought under the Colorado Consumer Protection Act (CCPA), third party insurance company’s duty to indemnify and duty to defend insured contractor.

Personal Injury: Experience representing drivers injured in auto accidents in dealing with at-fault drivers and insurance companies, negligence standard and negligence per se, reviewing policies for policy limits and available coverage, liability insurance and bodily injury insurance, uninsured and underinsured motorist coverage (UM/UIM policies), statute of limitations issues and collateral source law / defendant’s entitlement to a setoff, drafting effective demand letters setting forth damages in clear, unequivocal terms for input by claims adjusters into claims-valuation software like COLOSSUS, damages for medical expenses, extent of defendant’s liability, damages for medical expenses, lost wages and future earnings, pain and suffering, loss of enjoyment of life; independent medical examinations (IMEs), physician-patient privilege and waiver of privilege, maintaining privilege logs and electronic discovery, subrogation, Employee Retirement Income Security Act (ERISA) subrogation for self-funded plans and liens, settlement negotiations with claims adjusters and defense counsel, expert and non-expert witness depositions of treatment providers and billing administrators, bad faith claims and unreasonable conduct claims against insurance companies.

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