Work With Me

How I can help you:

Case evaluation:

  • Research, evaluate, and develop litigation strategies.

Pre-Trial:

  • Research and draft pretrial motions pertaining to jurisdiction, venue, discovery, expert challenges, etc.
  • Research and draft dispositive motions and responses to dispositive motions (summary judgment motions, motions to dismiss under the Texas Citizens Participation Act, motions to dismiss under Texas Rule of Civil Procedure 91a)

Trial:

  • Draft jury charge
  • Draft motions in limine
  • Draft trial briefs
  • Draft motions for directed verdict
 Postjudgment:

  • Draft post-judgment motions such as JNOVs, motions for new trial and other post-trial motions.
  • Evaluate appellate issues

Appeals: Many trial attorneys have little to no appellate experience and/or find the appellate process tedious or daunting. I can handle every step of an appeal as co-counsel, such as:

  • Evaluate appellate issues
  • Create the appellate record
  • Draft appellate motions such as motions to dismiss
  • Draft appellate briefs
  • File documents with the appellate court
  • Present oral argument to the appellate court

What I Use:

I use Westlaw. I have a nationwide plan, so I can perform legal research in any U.S. jurisdiction. I do not charge any extra fees for Westlaw unless I need to go outside my plan for your project. I use password protected cloud-based services for project management and file sharing to make collaboration easy, efficient, and organized. However, if you prefer to use other collaboration methods, I will be happy to use them. I use Microsoft Word and Adobe Acrobat Pro.

Billing:

I charge flat fees and hourly (with a minimum). I start work after receipt of a retainer/deposit (or the flat fee) for the project.

Like a court reporter or expert witness, I contract with the firm hiring me, so the firm is responsible to pay my fees. You determine how to inform and get reimbursement from your client for my work. Please refer to the ethics rules and opinions in your jurisdiction to guide you, e.g. Ethics Opinion 577 issued by the Professional Ethics Committee for the State Bar of Texas for Texas attorneys, and American Bar Association Standing Committee on Ethics and Professional Responsibility Formal Opinion 08-451 may apply to non-Texas attorneys.

Confidentiality:

Even though I do not have a contract with your client, I keep confidential all information shared with me. Your client remains, at all times, your client. You maintain the relationship with your client. I do have any contact with your client. I do not solicit your client.

Location:

I work remotely from my office located in northwest Austin, Texas.