Please do not hesitate to reach out for writing samples relevant to your practice/project. I am happy to share redacted pleadings, briefs, letters, etc. upon request.

That said, out of an abundance of caution for the confidentiality of my clients, and for the protection of my own work product, I do not post publicly available writing samples.

In lieu of that, I have provided the following outline of my standard practice as it relates to common legal writing tasks.

General Matters

I am a stickler for court rules. Especially if I am writing in a new jurisdiction, or one I do not work in often, I begin with a review of applicable court rules. In federal court, that generally means the federal rules of procedure and local court rules in the applicable district. In state court, that generally means the state-wide rules published either by the state supreme court or the legislature and the local rules of the applicable county or district. I welcome any available feedback from hiring firms/attorneys as to matters of local practice, and I try to incorporate formatting and style preferences of the hiring firms/attorneys wherever possible.

I am also a stickler for grammar, punctuation, spelling, and syntax. I strive for clarity in my writing, and I believe attentive and consistent use of basic English-language conventions are central elements of clear written communication in any context.

I do not use AI or “copy-and-paste” features to generate legal analysis. Full stop. Every portion of legal analysis will be personally drafted by me and custom-tailored to the applicable facts and law.

Pleadings, Motions, and Briefing

My approach to pleadings, motions, and briefing documents (including letters and other documents incorporating substantive legal analysis) was borne out my judicial clerkship and the approach I adopted for drafting appellate judicial opinions:

INTRODUCTION/PRELIMINARY MATTERS

JURISDICTION

FACTUAL BACKGROUND

LEGAL STANDARD/SCOPE OF REVIEW

ANALYSIS/DISCUSSION

CONCLUSION

I often alter this framework subject to the needs of a particular project, but this is always my starting point when it comes to formal legal documents incorporating substantive legal analysis.

In general, my pleadings (complaints/petitions and answers) and motions consist of concise, numbered paragraphs organized in accordance with the needs of the case. Complaints/petitions with multiple causes of action clearly delineate between them and incorporate standalone requests for relief upon proof of each cause of action. Likewise with motions containing multiple requests.

If drafting an answer, I try to mirror the numbering, formatting, and wording of the complaint to the extent possible. I then incorporate affirmative defenses and allegations as additional numbered paragraphs at the end of the answer.

Depending on the circumstances of a particular case, I have found it is sometimes effective to use standalone motion/briefs, which contain a “motion” section with concise numbered paragraphs and a “brief” section containing long-form legal analysis and citation.

I have drafted numerous pleadings, motions, briefs, letters, position statements and judicial opinions in my career. I will diligently review any information and documents provided by the hiring attorney/firm and convert that information into a concise recitation of the relevant factual background. I will then conduct exhaustive legal research and articulate your client’s strongest legal arguments with as much clarity and support as possible.

Discovery Requests/Responses

Beyond form or pattern discovery requests applicable to certain types of cases, I pride myself on crafting custom discovery requests targeted at specific allegations and claims. Because such requests are dependent on the circumstances and needs of a particular case, it is difficult to recite “standard” requests, but please do not hesitate to reach out to discuss targeted discovery requests for your matter.

Discovery responses likewise depend upon the circumstances and needs of a particular case, although, the following are some examples of standard objections/responses I often use:

·       [Plaintiff/Defendant] objects to this request on the grounds it is broad enough to encompass information and materials which are:

o   protected under the attorney client privilege and/or work product doctrines.

o   beyond the scope of discovery in this action/lawsuit.

o   confidential and/or proprietary, and an adequate protection order has not yet been entered in this action/lawsuit.

·       [Plaintiff/Defendant] objects to this request on the grounds the terms [X/Y/Z] are undefined and ambiguous as used in the request.

·       [Plaintiff/Defendant] objects to this request on the grounds it is a premature request for [contention interrogatories, trial exhibits, witness lists, etc]. [Plaintiff/Defendant] will supplement this response prior to trial and in accordance with any applicable court rules or orders of the Court.

·       Discovery is ongoing, [Plaintiff/Defendant] is further investigating this request, and this response may be supplemented accordingly.