Law & Motion
Demurrers / Amended complaints
Since no complaint is completely demurrer-proof, we draft and oppose a lot of demurrers. But sometimes a demurrer points out flaws that should be corrected anyway. If we think it would be more cost-effective, we may suggest that you amend the pleading instead.
Summary Judgment
Oppositions to motions for summary judgment are our bread and butter—we've opposed hundreds over the years. One employment-law attorney has sent us at least half a dozen in the past two years, and using our paperwork has prevailed on all but one. It’s been our experience that these motions often rest on shaky grounds, but we’re adept at finding triable issues of fact even in meritorious motions, saving your case for another day.
To prepare an opposition for you, we'll need the complaint and answer, the moving papers, and the complete deposition transcripts of any depo testimony defendants cite, and any other key discovery materials or facts for declarations. You'll get back all the documents you need to oppose the motion, including points & authorities, separate statements, draft declarations, objections to evidence, and a proposed order.
Other trial court matters
We prepare and oppose a full spectrum of trial court pleadings and motions. We do attorney fees motions and sanctions motions and anti-SLAPP motions. We draft criminal law motions, and family law and probate petitions of all kinds. Applications for TROs and preliminary injunctions, trial briefs, pocket briefs, motions in limine, and JNOV/new trial motions. Motions to compel arbitration or confirm awards, motions to compel discovery, tax costs, bifurcate, remand, change venue, appoint receivers ... and much more. We've seen it all.