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

*Right-click and click Save-As to download or save to your hard drive locally

ARIZONA :

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

CALIFORNIA :

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

FLORIDA :

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.

NEW YORK :

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.   

 OHIO :

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 Pleadings – complaint fails to allege requisite facts to support "mere continuation" theory of successor corporate liability.

 TENNESSEE :

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.

 VIRGINIA :

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.