![]() Prepare pretrial memorandums and motions in limine.Taken and defended over 100 party, fact and expert witness depositions.Attend mediations and pre-trial settlement conferences and negotiate settlement with opposing counsel.Draft and argue motions ranging from routine motions to substantive motions to dismiss and for summary judgment.Attend mandatory arbitrations, case management conferences, status conferences, motion practice and hearings.Handle a diverse caseload representing parties in state and federal litigation arising out of personal injury, employment matters, civil rights actions, products liability and construction defects.Presented the opening statement, examined witnesses and argued motions and jury instructions to a successful end. Sat second chair in a Federal Court civil jury trial. ![]()
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