The bolded links below contain motions drafted by me on behalf of various clients, and will hopefully give you a decent preview of my experience and abilities as a writer.
MOTION SEEKING SUMMARY JUDGMENT
This is a motion where various trucking company defendants successfully sought both traditional and no-evidence summary judgment as to all claims of plaintiff motorist, who was badly injured when she struck defendants’ legally parked tractor-trailer, during a period of intense sun-glare.
RESPONSE TO MOTION SEEKING SUMMARY JUDGMENT
In this response to the opposition’s motion for partial summary judgment, the plaintiff contractor succeeded in raising numerous issues of disputed fact concerning his agreement with defendants regarding the financing and control of a soured land development scheme.
Here, appellants succeeded on appeal in overturning trial court’s grant of summary judgment to a healthcare partnership regarding its vicarious liability for malpractice of member-physician.