Draft pleadings and motions including answers, application for determination of good faith settlement, and motion for protective order.Prepare for and attend mediations as first chair.Take and defend depositions (party and percipient witnesses), and conduct settlement negotiations.Interface with expert witnesses across various specialties, including accident reconstruction, human factors, neuropsychology, orthopedic surgery, and neurology.Assist in trial preparation, including drafting witness lists, jury instructions, verdict forms, and trial briefs.Coordinate with corporate clients, in-house counsel, and co-counsel regarding case strategy.

Acquired by Hawkins Parnell & Young

Second chair on two jury trials with responsibilities that included conducting voir dire and direct and cross-examinations of lay and expert witnesses.Drafted pleadings and motions including demurrers, motions to compel, and motions for summary judgment, and conducted comprehensive legal research.Managed all aspects of discovery, including taking and defending party, percipient witness, and expert depositions.Assisted in trial preparation, including coordination and preparation of experts, determined relevant trial documents, drafted motions in limine, exhibit lists, witness lists, jury instructions, verdict forms, statement of case, trial briefs, and coordinated with clients on case strategy. Served as mentor to junior associates, including revisions of work product.

Drafted complaints, demurrers, answers, motions to strike, motions to compel, and joint stipulations.Argued motions and oppositions before state and federal judges.Propounded and responded to discovery, as well as reviewed extensive document productions.Took and defended depositions of clients, third-party witnesses, and experts.Met and conferred with opposing counsel regarding discovery issues at the state and federal levels.Prepared exhibit lists, witness lists, jury instructions, and Central District L.R. 16 memoranda.Coordinated with clients and expert witnesses regarding case strategy and fact development.

Managed landlord-tenant disputes from inception through trial.Conducted unlawful detainer bench trials.Drafted and argued motions in unlawful detainer actions, including motions to compel, oppositions to demurrers, and motions for judgment on the pleadings.Propounded and responded to discovery in unlawful detainer actions.Negotiated settlement agreements and coordinated with clients regarding case strategy and analysis.

Conducted research on contract and real property mattersHeld Citation Appeal hearings and draft decisionsAssisted with construction of privilege log for discovery production

Researched and prepared Motion for SanctionsDrafted ex parte Motion for Advance Hearing and Proposed Order for Sanctions

Researched and drafted memoranda, argued motions, aided in creation of hearing exhibits, observed meetings with local, state, and federal law enforcement

Drafted grant deeds, Judicial Council Forms, petitions, and trust accountings.

Provided customer service, maintained floor stock, provided basic instruction of low brass instruments, sales and rentals of musical instruments.