MOTION TO MODIFY ORDER

mukiialice64
Motions
February 23, 2024

YOUR NAME

Street Address

City, State  Zip

Phone Number (with area code)

Fax Number (If applicable)

Email Address (If applicable)

In Pro Per

 

 

 

[NAME OF COURT]

[JURISDICTION]

 

NAME OF PLAINTIFF,

Plaintiff,

vs.

NAME OF DEFENDANT(s),

Defendant(s)

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 Case No.:

 

 

MOTION TO MODIFY ORDER AND TO ADMIT EVIDENCE

 

NOTICE OF DENISE LUNA’S MOTION TO MODIFY ORDER AND TO ADMIT EVIDENCE

You are hereby notified that on [Date], at [Time], Denise Luna will bring on for hearing her Motion to Modify Order and to Admit Evidence. It will be based on this Notice of Motion, the attached Motion to Modify Order and to Admit Evidence, exhibits adduced, and oral arguments presented during the hearing of the Motion.

 

Dated this _____ day of May, 20XX.

 

Respectfiully Submitted,

 

 

XXX

 

YOUR NAME

Street Address

City, State  Zip

Phone Number (with area code)

Fax Number (If applicable)

Email Address (If applicable)

In Pro Per

 

 

 

[NAME OF COURT]

[JURISDICTION]

 

NAME OF PLAINTIFF,

Plaintiff,

vs.

NAME OF DEFENDANT(s),

Defendant(s)

 )

)

)

)

)

)

)

)

)

)

 Case No.:

 

 

MOTION TO MODIFY ORDER AND TO ADMIT EVIDENCE

 

NOW COMES Denise Luna, and files this Motion to Modify Order and to Admit Evidence, and for cause would show this Honorable Court as follows:

  1. Denise Luna respectfully request an order to modify the existing order issued on [Date], and to present additional evidence that has recently come to her attention.
  2. As a party in this case, Denise humbly requests that the Court modify the current order in light of the new evidence that has been discovered.
  3. The evidence Denise is referring to includes a confirming laboratory statement, medical records showing that the test was never confirmed, and an expert witness report.
  4. These pieces of evidence are critical to Denise’s case because they provide new information that should be considered by the Court.
  5. The laboratory statement confirms that the previous test results were inaccurate and that an error occurred during the testing process.
  6. The medical records show that the original test was not confirmed, and therefore the results were not reliable.
  7. Based on this new evidence, it is apparent that the other records that were produced were not original and may have been altered or falsified.
  8. The confirming laboratory statement was obtained from an accredited laboratory and confirms that the previous test results were inaccurate.
  9. The laboratory statement is signed and dated by the laboratory director, who is a qualified professional in the field of laboratory medicine.
  10. The medical records that Denise has obtained show that the original test was not confirmed.
  11. The records were obtained directly from the medical provider and indicate that the original test was not reliable.
  12. The medical provider also provided a written statement confirming that the original test was not confirmed and was not reliable.
  13. Based on this new evidence, it is apparent that the other records that were produced were not original and may have been altered or falsified.
  14. It is clear that the previous test results were based on inaccurate information and that the results may have been altered or falsified.
  15. The new evidence calls into question the validity of the other records that were produced and suggests that they may have been altered or falsified as well.
  16. Denise believes that this new evidence should be taken into consideration by the Court in making a final determination in this matter.
  17. Therefore, Denise respectfully requests that the Court modifies the existing order to reflect this new evidence and any relevant changes that it may have on the case.
  18. In addition, Denise would like to request the opportunity to present this new evidence in a hearing or trial so that it can be properly evaluated and considered.
  19. Denise firmly believes that this evidence will have a significant impact on the case and will ultimately result in a fair and just outcome.
  20. Denise objects to the exercise of parens patriae jurisdiction because she believes that the trust established for the benefit of her offspring is no longer vested with the state. Luna requests that ecourt dismiss any action by the state to exercise parens patriae jurisdiction over the trust.

REASONS WHEREFORE, PREMISES CONSIDERED, Denise Luna respectfully requests this Court to Modify the current order issued on [Date], issue an order admitting the confirming laboratory statement, medical records showing that the test was never confirmed, and an expert witness report into evidence, and to grant Denise such equitable and further relief as this Court deems proper.

 

Dated this _____ day of May, 20XX.

 

Respectfiully Submitted,

 

 

Denise Luna

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