Services
Hands-on help with the substance of the case.
I take on defined projects, overflow work and continuing part-time assignments under attorney direction.
Discuss an assignment
01
Discovery
Written discovery and discovery disputes
I draft discovery with the pleadings, the known record and the case strategy in view.
- Form and special interrogatories
- Requests for admission
- Requests for production
- Verified response preparation and revision
- Deficiency analysis and meet-and-confer correspondence
- Informal discovery conference submissions
- Motion-to-compel papers and supporting materials
- Production review and evidentiary-gap analysis
02
Law and motion
Pleadings, motions and oppositions
Drafting starts with the procedural posture, the available evidence and counsel’s theory of the case.
- Pleadings and responsive pleadings
- Motions, oppositions and replies
- Discovery motions
- Declarations and evidentiary foundations
- Separate statements
- Requests for judicial notice
- Supporting memoranda and proposed orders
- Citation, record and procedural checks
03
Analysis
Research and evidence development
Focused research and record review to get to the rule, fact or evidentiary link that matters.
- California civil procedure and local-rule research
- Evidentiary research and foundation analysis
- Pleading, record and document-production review
- Witness and client interviews
- Declaration development
- Factual and legal issue development
- Exhibit identification and organization
- Targeted public-record and factual research
04
Completion
Filing-ready work product
I deliver clean, organized work so counsel can review the substance instead of rebuilding the file.
- Attorney-ready drafting and revision
- Exhibit sets and supporting papers
- Internal cross-reference and citation review
- Caption, formatting and signature-page checks
- Filing and service preparation
- Deadline and submission coordination
Representative matters
My civil matter experience includes:
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