Writing Samples

Enclosed for your review are writing samples prepared for clients in several different jurisdictions.    

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Complaint – multi-count complaint arising out of defendants' publication of defamatory statements regarding plaintiff's status as licensed physician. 


Due Diligence Memo – summary judgment procedural overview; "piercing corporate veil" substantive overview.   


Appellate Brief – seeking reversal of trial court's attorney's fee award on the basis that trial court failed to make requisite findings.    

Due Diligence Memo – vicarious liability of homeowner for actions of invitee who shot and injured homeowner's neighbor.


Due Diligence Memo I – availability of statutory civil theft remedy; analysis of common law conversion remedy.     

Due Diligence Memo II – analysis of motion to vacate judgment of conviction filed pursuant to CPL section 440.10.   


Motion to Dismiss individual defendant entitled to dismissal where record evidence proves that defendant signed subject agreement in representative capacity only.

Motion for Judgment on Pleadingscomplaint fails to allege requisite facts to support "mere continuation" theory of successor corporate liability.


Brief in Support of Motion to Declare Marriage Void Ab Initio defendant's bigamous Florida marriage violates Tennessee public policy and is therefore void ab initio.


Due Diligence Memo mutual mistake analysis regarding whether buyer or seller of pregnant cow is entitled to calf where neither party was aware of pregnancy at time of sale.