Data breach/employment class action litigation.

Diverse subject matter experience including wage and hour, PAGA/class action, whistleblower/wrongful termination, discrimination, Labor Commissioner hearings, traumatic injury, LTD denials Overview of Litigation Work:Pre-Litigation-Coordinates with clients to gather facts, documents, and chronology of case -Drafts settlement demand/PAGA letters to insurance companies and opposing attorneys-Drafts Civil Complaints (form and regular) and Answers-Conducts legal research on substantive, procedural, and evidentiary issuesDiscovery-Propounds Interrogatories, Document Requests, Admissions in Wage & Hour, Employment Discrimination, Contract Disputes/General Litigation, and Personal Injury cases-Works with clients to respond to discovery requests; drafts and revises discovery responses-Coordinates with opposing counsel on discovery issues-Reviews and organizes produced documents -Drafts responses to Demand for Exchange of Experts and coordinates with expert witnessesDepositions-Prepares clients for depositions-Defends and takes depositions Law and Motion-Drafted successful oppositions to Motions for Summary Judgment-Drafts motions/oppositions including Demurrers, Trial Continuances, Motion to Compel, Motion to Disqualify, Class Action Certification -Appear at CMC/OSC/Ex Parte hearings in state and federal court-Appear and argue motions in court Trial-Represent clients at small claims appeals and Labor Commissioner appeals (trial de novo) -Drafts and revises Motions in Limine, Verdict Forms, Trial BriefsSettlement and Mediation-Develops Excel spreadsheets to formulate/organize damages calculations-Negotiates settlement proposals with opposing counsel and insurance companies-Drafts mediation briefs, reviews settlement documents-Attends settlement conferences on behalf of clientsOther: California Labor Commissioner -Represents clients at settlement conferences and hearings before the California Department of Labor

Helps student authors develop original scholarly works that will benefit the legal community. Coordinates law review policy with the Board of Editors, including selection and promotion of staff writers.

Legislative Staff Writer: • Researched, analyzed legislative history and impact of recently passed California legislationComment Staff Writer: • Developed and published original scholarly work on constitutionality of juvenile sentencing practices

• Drafted various civil and administrative pleadings, subpoenas, trial motions, consent orders and other settlement documents, criminal referrals, investor questionnaires, and research memos on potential violations of California securities laws• Assessed case files to determine whether a case exists and the nature of any enforcement action, makes recommendations to Deputy Commissioner • Drafted multiple settlement documents for $17 million judgment under emergency conditions• Interpreted statutes, analyzed potential legislative/policy changes

Managed and designed largest section of award-winning weekly student newspaper. Researched relevant, informative articles; assigns writers to cover stories. Sunday layout sessions typically lasted 12 hours. Final product is a clean, attractive design. In addition, also wrote articles for the paper on a weekly basis. See Staff Writer position below for more information.

Works one on one with undergraduate students to strengthen their writing skills. Analyzes papers for patterns of error in order to provide optimal feedback and student satisfaction.

Worked with English professor to train and refine students’ argumentative writing styles. Led class session on advanced quotation techniques.

Writes monthly “On the Net” column for local Bay Area paper. Researches, describes and reviews current Web trends in succinct, informative matter.

Helped edit, compile, and manage the 2009 Business as UNusual guide, which lists graduate business schools that integrate elements of corporate social responsibility and environmental sustainability into their curriculum.

Compiled, data entered and analyzed survey forms for midsized nonprofit. Streamlined databases for easy access; created graphs used in regional directors’ meeting.

Interviewed College officials and visiting speakers. Wrote numerous 500+ word features such as drug culture, disciplinary process and scholarships.