DISCOVERY

The pipeline to success in litigation or trial is discovery. Critical facts and evidence are buried deep within the thousands of pages of documents and testimony waiting to be discovered or avoided. I draft code-compliant discovery and corresponding responses, including:

• Form Interrogatories

• Special Interrogatories

• Requests for Admission

• Request for Production of Documents

• Discovery Summaries and Meet & Confer Letters

• Medical Records Summaries and Timelines

• Page:line summary of depositions; hearing and trial transcripts

LITIGATION

Every successful litigator recognizes the importance of understanding the anatomy of litigation. From the birth of a lawsuit, up to and including the date of trial, key and vital legal strategies are put into play with the sole objective of securing success via a positive settlement or jury verdict. Law and motion sets the rhythm of litigation. When planned intelligently, litigation should flow smoothly through its vines. However, when indecision and poor choices are made, litigation will come to a halt and bottleneck like L.A. traffic on the 405. I am a strong writer and employ superior research and analytical skills. I draft signature-ready pleadings including:

• Complaint and corresponding Answer

• Motion for Summary Judgment/Opposition

• Motion to Strike/Opposition

• Demurrer/Opposition

• Discovery motions to compel

• Rule 12(b)(6) and Rule 12(b) (1) Motions

TRIAL

It’s all fun and games until the reality of Trial is imminent. I have prepared hundreds of cases for trial and attended and assisted counsel at trial in state and federal court on 46 occasions.

NO DADDY BALL HERE - - BRING IT!!