Including but not limited to: Legal Research; Draft Summons and Complaint, Bill of Particulars, Response to Discovery and Inspections, Motions, Oppositions to Motions (including Threshold Motions, Motion to Vacate Note of Issue, Motion to Dismiss on Liability Issues, etc.), Order to Show Cause, etc.; Chinese-English and English-Chinese Translations; Contact with Chinese clients.

Participated in the legal investigation and research of inmate claims of actual innocence. Conducted interviews of inmates and possible witnesses. Using primary sources including police and forensic reports, court pleadings, transcripts, appellate briefs and opinions, researched and prepared written summaries of the cases referred to the Clinic by the Mid-Atlantic Innocence Project (MAIP). The case analysis and investigation results are used as a basis for MAIP to determine which cases to undertake.

Conducted legal research on search and seizure, contract fraud, drug abuse, and illegal firearm possession. Drafted sentencing motions, ex parte motions for indigent defendants, and jury instructions. Conducted jail visits and client interviews. Assisted with expert witness and discovery research. Organized legal memoranda and client correspondence.

Researched legal issues including conversion of real property, trusts,wills and, estates, workers’ compensation and defense of criminal cheat. Drafted appellate brief dealing with wrongful termination. Drafted answer for criminal prosecution. Interviewed with client and witness. Assisted with representation of clients wrongful discharge and divorce trials.