Erica Lavarnway Email & Phone Number

Dallas-Fort Worth Metroplex

Dallas, Texas, Us

• Drafted Daubert/Robinson motion, other motions to strike, motion to enlarge time, response to motion to remand, motion to dismiss and jury charge.• Researched and wrote legal memoranda on various issues including proportionate responsibility, fiduciary duty, abatement, third-party claims, and attorney’s fees.

• Drafted trust documents including personal asset trusts and irrevocable grantor trusts. • Drafted estate planning documents including the power of attorney, living will, and pourover will. • Communicated with clients.

• Researched and wrote legal memoranda on on issues specific to labor and employment, including breach of fiduciary duty, usurpation of corporate opportunity, and exemptions to overtime pay.• Researched and wrotte legal memoranda on various aspects of litigation, including temporary injunctions, pleading requirements, removal, forum selection clauses, and jurisidiction.• Drafted pleadings, including petitions, answers, motions to compel, motions for sanctions, a special appearance, response to motion for summary judgment and appellate brief. • Drafted outgoing requests for production, requests for admission, requests for disclosure, interrogatories, and responses and objections to discovery requests.• Performed initial client intake.

Mercedes, Texas, Us

• Drafted pleadings and motions.• Communicated with clients.• Assisted with discovery.

• Conducted research on premarital agreements, military retirement, spousal maintenance and other family law matters.• Drafted motion for summary judgment and response to motion for summary judgment.• Communicated with clients.

• Drafted pleadings and other documents.• Assisted with research in family law and probate matters.• Communicated with clients and opposing counsel.• Drafted discovery requests and responses.

Doctor Of Law (J.D.)

Bachelor Of Arts (B.A.), Communication, General