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Elder Justice Prosecutor Samples

Find publicly-filed, sample elder abuse federal and state pleadings and documents. PACER citations have been provided where available.
Displaying 176 - 200 of 1552
Amended Complaint and Jury Demand, , 3 pgs
Trial Pleadings

Alleges elder abuse; requests judgment against defendant, damages under consumer protection code, costs, attorneys' fees and jury trial

(Intentionally Left Blank)

Colorado
Amended Complaint and Jury Demand, , 4 pgs
Civil Case Pleadings & Materials

Alleges: contract for sale of vehicle to vulnerable disabled adult void; abuse of an elderly person; violation of consumer protection code. Requests jury trial (2011)

Colorado
Motion to Amend Counts One Through Seven, , 3 pgs
Civil Case Pleadings & Materials

Requests amended charges: Charges 1 Count: theft from an at-risk adult over $5000; Charges 7 Counts: theft (2005)

C.R.S. §18-6.5-103(5) and §18-4-401(1)(a)(b), (2)(d) and §18-4-401(1)(a), (2)(c )

Colorado
Bill of Particulars, , 3 pgs
Indictments & Informations

Charges 1 Count: theft from an at-risk adult over $500; Charges 7 Counts: theft; Charges 7 Counts: breach of fiduciary duty (2005)

C.R.S. §18-6.5-103(5) and §18-4-401(1)(a) and (b), and §38-22-126

Colorado
Defendants' Post Trial Brief, , 20 pgs
Other Materials

Argues Court must grant Motion for Dismissal or, in the alternative, enter judgment for defendants because plaintiff is barred from recovery and enrichment by an illegal contract

Conn.Evid. Code §4-1 and Conn.Gen.Stat. §20-679 and §20-678 and §20-670 to §20-680 and §1-2z and §1-1(a) and §20-429 and §20-429(a), (a)(1) and §20-627 and §20-670-3 and §42-135a and §42-134a, et al. and §42-134a(a), (b) and §20-325a(a) and §52-572(c) and §20-670-3(b) and Conn.Regs. §20-670-3

Connecticut
Brief of Defendant-Appellee, , 11 pgs
Other Materials

Argues Court must deny appeal and uphold Trial Court decision because judgment of foreclosure was open so default could be set aside

Conn.Gen.Stat. §1-2z and §49-15 and §49-15(b) and §52-212 and §52-212a and Conn. R.App. Proc. §62-7 and §67-2

Connecticut
Plaintiff's Reply Brief, , 8 pgs
Other Materials

Argues Court must rule in plaintiff's favor on Counts Two and Three of Second Revised Complaint, award damages plus statutory interests and costs; requests Court find defendant's remaining Counterclaims and Special Defenses fail to meet burden of proof

Conn.Gen.Stat. §52-29 and §47a-1

Connecticut
Defendant's Brief Regarding Hearsay Testimony, , 30 pgs
Other Materials

Argues Court must find this a case of elderly abuse and defendant entitled to setoff for labor and materials; requests punitive damages to include litigation expenses and attorney fees less taxable costs which, if recovered, would be included in judgment

Conn.Gen.Stat. §47a and §34 and §34-301 and §34-300-434 and §34-314 and §34-300-399 and §34-303(b), (c)(1) and and §34-305 and §34-337(b) aand §34-338(b), (c), (d) and §34-357(b)(3) and §34-356(a) and §34-355 and §34-355(1), (5) and §34-372(4), (5), (6) and §34-338(a), (b), (c) and §34-327(c) and §34-322 and §34-322(h), (j) and §52-564 and §53a-119

Connecticut
Brief of Plaintiff/ Appellee, , 15 pgs
Other Materials

Argues Court must affirm judgment of Appellate Court vacating Arbitrator's award reinstating grievant and reversing Union's application to confirm Arbitration award; requests, if judgment is reversed, Court remand case to Appellate Court for determination on appellee's claim Arbitrator exceeded his authority

Conn.Gen.Stat. §19a-550(b)(8) and §17b-451

Connecticut
Defendants, Reliable Care, LLC & Helen Jetter's Post Trial Brief, , 19 pgs
Other Materials

Argues Court must find in defendants favor on all liability issues because plaintiff failed to present a prima facie case of negligence

Conn.Gen.Stat. §31-130 and §34-133(a) and §35-1 and §35-1(a) and §20-670 and §20-670(6) and §20-671 and §20-670 et seq. and §20-678 and §20-679

Connecticut
Revised Third Amended Complaint, , 6 pgs
Trial Pleadings

Alleges: defendant ignored demand for plaintiff's financial affairs accounting; defendant's fraud impoverished plaintiff; defendant violated fiduciary duty to plaintiff; defendant owes plaintiff punitive damages; requests an independent accounting of securities held solely and jointly in defendant's and plaintiff's names, judgment awarding damages equal to amount plaintiff was defrauded and punitive damages for willful elder financial exploitation

(Intentionally Left Blank)

Connecticut
Complaint, , 5 pgs
Trial Pleadings

Alleges duty abandonment, negligence, failure to follow proper policies and procedures and breach of standard of care; requests monetary damages for serious, painful and permanent injuries to an elderly woman

(Intentionally Left Blank)

Connecticut
Memorandum of Law in Support of Defendant's Motion for Summary Judgment, , 16 pgs
Trial Pleadings

Recommends Court grant motion because there is no material fact issue, there is no basis for a constructive trust and plaintiffs' claim is barred by doctrine of laches and Marketable Title Act

Conn.Gen.Stat. §52-550 and §47-33b et seq. and §47-33b(a), c, d, e, b(e) and §45a-450

Connecticut
State's Motion to Consolidate, , 2 pgs
Trial Pleadings

Requests Court consolidate and jointly try cases involving promissory notes issued to two elderly women because severance of the two matters is not necessary to prevent prejudice, non violent theft and security violations are charged and evidence in both cases can be presented in six days or less

Conn.Gen.Stat. §54-57

Connecticut
Memorandum of Law in Support of Defendant's Motion for Summary Judgment, , 16 pgs
Trial Pleadings

Requests Court grant motion for summary judgment because: there is no written agreement or basis for a constructive trust; claim is barred by doctrine of laches and by Marketable Title Act (2010)

Conn. Gen. Stat. §52-550 and §47-33b et seq. and §47-33e and §47-33b(a) and §45a-450 and §47-33c and §47-33d and §47-33e and §47-33b(a) and §47-33b(e)

Connecticut
Revised Complaint
, , 3 pgs
Civil Case Pleadings & Materials

Alleges tortious interference with a financial expectancy. Requests judgment on parties' rights and responsibilities (2009)

Connecticut General Statutes §52-29 and §17-54 et seq.

Connecticut
Plaintiff's Post-Trial Memorandum, , 9 pgs
Trial Pleadings

Affirms breach of fiduciary. Requests Court find demand for accounting, fraud, fraudulent conversion, theft, punitive damages and remedy if statute of limitations expired (2008)

Conn. Gen Stat. §52-564 and §53a-119 and §52-595 and §52-577

Connecticut
State's Sentencing Memorandum, , 9 pgs
Sentencing Memoranda

Requests: ten years' incarceration; suspension after five years; five year probationary period; $3,307 restitution to elderly financial exploitation victim's estate (2007)

Connecticut Practice Book §43-11; Connecticut Practice Book §43-28

Connecticut
Complaint, , 3 pgs
Trial Pleadings

Alleges financial exploitation of vulnerable adult by forgery, conspiracy and theft (2003)

Connecticut
Memorandum of Points and Authorities in Support of Plaintiff's Motion in Limine, , 3 pgs
Trial Pleadings

Recommends Court grant motion because prejudicial evidence should not be allowed in this elderly plaintiff's pension agreement case

(Intentionally Left Blank)

District Of Columbia
Memorandum of Points and Authorities in Support of Plaintiff's Reply to Defendant's Opposition to Plaintiff's Motion for Summary Judgment, , 5 pgs
Trial Pleadings

Recommends Court grant summary judgment because defendant has failed to provide: an affidavit; statement of material facts in dispute; defenses to promissory estoppel or breach of contract

Sup.Ct.Civ.R. 56(e) and 12-I(k)

District Of Columbia
Memorandum of Points and Authorities in Support of Plaintiff's Motion for Summary Judgment, , 6 pgs
Trial Pleadings

Recommends Court grant motion because there are no material facts at issue: elements of promissory estoppel are present; the pension is a valid unilateral contract

Sup.Ct.Civ.R. 8(a)

District Of Columbia
Washington Metropolitan Area Transit Authority's ("WMATA") Response Brief to Plaintiff's Memorandum of Law on the Defendant's Standard of Care, , 2 pgs
Other Materials

Argues Court must hold plaintiff's memorandum is not evidence of duty of care negligence because memorandum fails to offer legal support for argument WMATA had an existing duty to ensure an elderly passenger remained seated before moving the bus

(Intentionally Left Blank)

District Of Columbia
Defendants' Reply in Support of Motion to Dismiss Plaintiff's Complaint, , 7 pgs
Trial Pleadings

Requests Court dismiss complaint with prejudice because allegations fail to: support exception to employment-at-will doctrine; state claim under District of Columbia Human Rights Act; state claim for intentional infliction of emotional distress; assert claim for negligent hiring and supervision

(Intentionally Left Blank)

District Of Columbia
Petitioner's Memorandum of Points and Authorities in Opposition to Motion to Intervene, , 13 pgs
Trial Pleadings

Recommends Court deny motion and approve petition for cy pres because: movants are not qualified to assert the public interest; movants lack standing to require a financial accounting or to remove directors; proposed transactions would jeopardize and degrade the Corcoran

D.C. Code §19-1301.03 and §19-1304.05, 13 and §29-401.02(24), .05, .22 and §29-406.09 and §29-410.01, .03 and §29-411.02 and D.C. Code art. 29, Ch. 4

District Of Columbia
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