Legal Services

Freelance Paralegal $35/Hr. (Attys Only) 25+ Yrs CA Civil Lit

26 Years CA State & Federal, Defense & Plaintiff-Trial, Appellate & ADR

Extensive Boilerplate Library- Past Pleadings, Motions, Discovery Requests, Objections etc…

Full-Featured Home Office – Print, Scan, Copy, Fax

Lexis/Nexis (Westlaw Available on Special Projects), VerdictSearch

Law Office Tech-Evaluation, Installation, Management, Repair/Troubleshooting

Writing Samples Provided on Request

California Civil Litigation

Complaints, answers, demurrers and motions to strike, discovery, motions to compel, protective orders and motions to quash, summary judgment, motions for reconsideration, §3295 motions, alter-ego motions, interpleaders, declaratory relief, injunctions, motions for stay, equitable causes/defenses, equitable tolling, §473 relief, anti-SLAPP, motions for good faith settlement, §998 and §664.6 motions

Federal Civil Litigation

Complaints, answers, Rule 12 dismissals, class certification, Rule 56 summary judgment, ENE briefs, Rule 26 initial disclosures, discovery plans and orders, discovery requests, responses, motions to compel/protective orders, Civil RICO pleading, case statements, trial preparation, post-trial motions

Trial

Trial preparation – authentication, organization of evidence, TRC reports, motions in limine, voir dire challenges, witness qualification, and post-trial motions for new trial/NOV, costs, attorney fees, addittur/remittur including Howell and MICRA issues)

Appeal

Notices of Appeal, Briefs, Remand, Costs/Sanctions, Cert Petitions, Writ Requests

ADR

Arbitration (AAA commercial, UM/UIM) procedure, petitions to compel/oppositions, motions to set aside or confirm award, motions to compel appointment of arbitrator/disqualify arbitrator, numerous mediations and settlement negotiations

Practice Areas

Torts/personal injury (auto, slip and fall, product liability, property damage, fraud, Federal Tort Claims Act and state public entity liability, class actions), legal malpractice, medical malpractice, professional negligence/misconduct (accounting, real estate), contracts and business disputes, business formation, labor and employment law, family law, harassment and discrimination claims (FEHA, Title VII, ADA, ADEA), civil rights/Bivens cases, principal/agency, insurance bad faith, breach of fiduciary duty, fraudulent transfers, declaratory relief, elder abuse, civil RICO, privacy, nuisance,§17200 actions, malicious prosecution, SLAPP, private attorney general, administrative mandamus. Limited experience with bankruptcy, workers compensation and intellectual property.

Pre-Litigation

Intake, file prep/setup, claims presentation, obtaining medical, business, employment records, demand preparation, settlement negotiation, settlement/release procedures

Technical Skills

Wordperfect, Office-Word, Outlook, Excel, Access, PowerPoint, GoogleDocs, OpenOffice, Dropbox, Prolaw, Abacus, Amicus, MyCase, Clio, RocketMatter, CaseLogistix, Concordance

Technician-level familiarity with all Windows-based systems and Android-based devices. User-level familiarity with Apple/Mac/IOS systems.

Programming custom office solutions for user-friendly and secure data management (desktop, laptop and web/cloud-based)

Windows (All versions including 2000, XP, Vista, Windows 7, Windows 8); Old/Legacy Systems (Unix/MS-DOS)

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