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Browse 455 motion patterns extracted from federal court filings across 94 district courts. Each pattern captures argument structures, citations, evidence strategies, and win rate signals from real litigation outcomes.
Showing 433–455 of 455 patterns
defendant requests the government to disclose any evidence it intends to introduce under rule 404(b) regarding prior or subsequent criminal conduct or "bad acts" not charged in the indictment.
defendant needs adequate time to prepare objections before trial, necessitating a court-ordered deadline for the government's 404(b) notice.
counsel should be prohibited from arguing for jury nullification.
counsel should be prohibited from referencing potential sentences or consequences resulting from a conviction.
argument or testimony indicating victims' naivety, carelessness, negligence, greed, foolishness, or unreasonable reliance on the statements of the defendant does not constitute a defense to wire fraud
Rule 404(b) of the Federal Rules of Evidence
United States v. Kreimer, 609 F.2d 126, 132 (5th Cir. 1980)
United States v. Lucas, 516 F.3d 316, 339 (5th Cir. 2008)
United States v. Svete, 556 F.3d 1157, 1165 (11th Cir. 2009)
United States v. Thomas, 377 F.3d 232, 242 (2d Cir. 2004)
RELIEF REQUESTED → COURT'S PRIOR DISCOVERY ORDERS (2023) → SANCTIONS HEARING (FEB. 2024) → ESI SANCTIONS ORDER (DKT. 111) → ESI PRESERVATION ORDER (DKT. 118) → URZ FAILED TO COMPLY (PRE-INSPECTION) → URZ FAILED TO PRESERVE ESI (PRE-INSPECTI → SITE INSPECTION AND ESI COLLECTION
I. INTRODUCTION → II. GROUNDS FOR SANCTIONS → A. CONTRADICTORY STATEMENTS REGARDING SU → B. POST-TERMINATION COMMUNICATIONS → C. MISCHARACTERIZATION OF PERFORMANCE AN → III. LEGAL BASIS → IV. PRAYER
PLAINTIFF MOTION FOR SANCTIONS PURSUANT → TO THE HONORABLE JUDGE OF THIS COURT: → STATEMENT OF ISSUES AND ORDER → STANDARDS OF REVIEW → FACTUAL BACKGROUND → ARGUMENT → CONCLUSION → CERTIFICATE OF COMPLIANCE WITH WORD COUN
I. BACKGROUND → II. BASIS FOR SANCTIONS → A. BAD FAITH LITIGATION CONDUCT → B. VIOLATIONS OF THE FAIR DEBT COLLECTIO → C. VIOLATIONS OF UCC ARTICLE 9 → D. VIOLATIONS OF THE TEXAS DECEPTIVE TRA → III. RELIEF REQUESTED → IV. PRAYER
PLAINTIFF'S NOTICE OF X CORP'S MATERIALL → TO THE HONORABLE COURT: → I. X CORP'S FALSE STATEMENT → II. THE THREE-SCREENSHOT PROOF → III. THE CONTRADICTION → IV. HOW THE "AFFILIATED WITH X" BADGE WO → V. VERIFICATION AVAILABLE IN 30 SECONDS → VI. THE MESSAGE THIS COURT IS SENDING
defendant engaged in bad faith litigation conduct by repossessing and selling the vehicle after the lawsuit was filed, knowing the account was not in default.
defendant violated the fair debt collection practices act (fdcpa) by repossessing property without a present legal right to do so, as the account was current.
defendant violated ucc article 9 by failing to conduct the sale in a commercially reasonable manner and by not providing advance written notice of the sale.
defendant violated the texas deceptive trade practices act (dtpa) by misrepresenting the account status and failing to disclose material facts regarding the debt's satisfaction.
x corp made a materially false statement to the court regarding account affiliation in its opposition to plaintiff's rule 60(b)(3) motion.
mr. kennedy's opinion that ecofactor's proposed per-unit royalty is an established royalty should be excluded because it is unsupported by reliable methodology or sufficient facts.
mr. kennedy's opinion that ecofactor's proposed per-unit royalty is a per-unit reasonable royalty must also be excluded because the licenses upon which he relied are not comparable.
mr. kennedy failed to perform any calculation to show that ecofactor's proposed per-unit royalty had been applied as a per-unit royalty, rendering his opinion unreliable.