Examples of Motions and Responses

Below is a list of sample motions, responses to motions, and a few court orders. Sometimes, you have to reinvent the wheel when drafting legal documents but sometimes you do not. These examples can be use in whole or in part or may just give you ideas as to what might work for your pleading and how to write them.

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Shortcuts to Motions by Categorymotionnewtrial

Pre-Discovery Motions

  • Consolidate Cases: This is a motion to merge two related causes of action [Select here]
  • Service by Alternative Method: Sometimes, you just can't track down the defendant. Maryland allows for alternative service if certain hoops have been jumped. [Select here]
  • Defendant's Motion to Transfer Venue [Select here]
    • Our response: This is our latest effort at fine tuning our forum non conveniens arguments. We won this motion and got a $5.5 million verdict
    • Court's order
  • Opposition to Motion to Dismiss for Improper Venue: This was a venue battle over the more specific factual issue of whether defendant was doing business in the jurisdiction in which we brought the claim. He claimed he did not. Our private investigator found that he did. [Select here]

Discovery Motions

  • Compel Discovery Responses: Standard filing to get other party to answer discovery. Normally, the response is just providing the answers. [Select here]
  • Response to Motion to Compel a Defense Medical Exam: We generally do not oppose the exam itself. The battle is usually over the conditions of the exam or the expert's failure to provide financial information [Select here]
    • Another Response to Motion to Compel Physical Examination [Select here]
    • Defendant's Motion to Compel a Physical Exam (citing IME "handbook") [Select here]
  • Compel Deposition: Defense counsel with increased frequency instructs the defendant not to answer questions, usually because they don't like the. This motion requests a second deposition at defendant's expense. [Select here]sample legal motions
  • Plaintiff's Response to Motion to Compel Medical Records Authorization: Many defendants want to go around HIPAA and get the records from the medical providers. They can do this with a subpoena, not a blanket HIPAA authorization.. [Select here]
  • Opposition to Motion to Compel Vocational Rehabilitation Expert Interview: Defense counsel wanted to give the voc rehab expert a chance to essentially depose the plaintiff again. [Select here]
  • Expedited Discovery: With a pending statute of limitations looming, you want to make sure you have all of the appropriate parties in the case. This speeds the process along if defense counsel is dragging their feet.[Select here]

Expert Motions

Motions for Summary Judgment/Motions to Dismiss

Motions in Limine

Post Trial Motions

  • Response to Motion for New Trial/Remittitur (premises liability)
    • Defendant's Motion for Remittitur [Select here]
    • Plaintiff's Response to Motion for New Trial/Remittitur, (premises liability) This was a $377,000 verdict on $6,000 in medical bills. We fought to keep the verdict. The judge did reduce the judgment to $250,000 [Select here]
    • Defendant's Response to Plaintiff's Response to Defendant's Motion for Remittitur [Select here]
  • Plaintiff's Opposition to Motion for J.N.O.V. or Motion for a New Trial [Select here]
      • Defendant's Motion for J.N.O.V. or In the Alternative, Motion for a New Trial. This was based on allegation of juror misconduct. The motion failed. [Select here]
      • Plaintiff's Reply to Defendants Reply to Plaintiff's Opposition to Motion for J.N.O.V. or In the Alternative, Motion for a New Trial [Select here]
      • Defendant's Reply to Plaintiff's Opposition to Motion for J.N.O.V. or In the Alternative, Motion for a New Trial [Select here]
    • Response to Motion for a New Trial [Select here]
    • Opposition to Motion for New Trial [Select here]
    • Response to Defendant's Motion to Revise Judgment [Select here]
    • Judgment Notwithstanding the Verdict [Select here]
    • JNOV (supplemental motion) [Select here]
    • Defendant's Motion for Remittitur [Select here]
    • Defendant's Response to Motion for Remittitur [Select here]
  • Plaintiff's Opposition to Motion for J.N.O.V. or Motion for a New Trial [Select here]
    • Defendant's Motion for J.N.O.V. or In the Alternative, Motion for a New Trial [Select here]
    • Plaintiff's Reply to Defendants Reply to Plaintiff's Opposition to Motion for J.N.O.V. or In the Alternative, Motion for a New Trial [Select here]
    • Defendant's Reply to Plaintiff's Opposition to Motion for J.N.O.V. or In the Alternative, Motion for a New Trial [Select here]
Related Links
  • Review Sample Discovery (interrogatories, depositions, trial transcripts, and much more)
  • Get Help! (forms, pleadings, examples)
  • Information for Lawyers Seeking To Refer Miller & Zois a Personal Injury Case (information for referring lawyers)