qj

Additional documents will be added to this archive from time to time. They are cross-referenced as follows:

• By document type
• By subject matter

---

By document type:

Memos

• Drafting a complaint against a telephone company
  
• Attorney's fees and punitive damages in section 1983 action
  
• Memo re Dept. of Labor jurisdiction re Fair Labor Standards Act
  
• Memo re claim for payment of certificates of deposit
  
• Family law memorandum
  
• Insurance coverage; duty to settle; effect of bankruptcy on judgment
  
• Memo re mall's liability for pit bull mauling
  
• Memo re liability for failure to pay employment taxes
  
• Memo re failure to build foundation according to specifications
  
• Memo re effect of amending a trust
  
• Memo re liquidated damages provision in North Carolina
  
• Memo re community interest in restricted stock and unvested options
  
• Memo re joint tenancy account and undue influence
  
• Memo re store's liability for detaining employee on suspicion of theft
  
• Memo re liability for taking a competitor's employees
  
• Memo re proving lost profits
  
• Memo re unfair debt collection practices
  
• Memo re rental car co. insurance liability
  
• Memo re prepayment penalty
  
• Memo re attorney's fiduciary duty
  
• Memo re strict liability for chimp attack
  
• Memo re broker's right to commission: lease/option
  
• Memo re lien sale of joint tenant's interest
  
• Memo re joint tenant's contribution to down payment
  
• Memo re liability for wrongful death; strict liability
  
• Memo re personal injury; landowner liability
  
• Memo re real property; leases; condemnation
  
• Memo re RICO liability
  
• Memo re trademark genericness -- Surgicenters case

 

Mediation briefs

• Plaintiff's mediation brief -- check-cashing fraud
  
• Mediation brief -- failure to disclose defects in sale of real property
  
• Mediation brief -- failure to disclose offsite landfill in sale of real property
  

 

Briefs in trial courts

• Opposition to Demurrer - Plaintiff properly pleaded fraud and intentional infliction of emotional distress in sale of her business
  
• Opposition to motion to dismiss
  
• Plaintiff's opposition to motion for summary judgment - sex discrimination
  
• Opposition to motion for summary adjudication - discrimination based on age, ancestry, and religion
  
• Motion to compel production of documents - Nevada
  
• Plaintiff's Points & Authorities in opposition to Motion for Summary Judgment - insurer bad faith
  
• Defendant's Points & Authorities in support of motion to exclude evidence
  
• Demurrer - subcontractor not a party to the principal's contract
  
• Commercial landowner's liability for assault on patron
  
• Failure to correct leaseholder's flooding problem negates contract
  
• Point's & Authorities in support of motions to dismiss and strike - trademark issue
  
• Plaintiff's Motion for Summary Judgment & reply - insurer's duty to defend
  
• Motion in limine to exclude expert's testimony
  
• Opposition to demurrer - premises liability
  
• Plaintiff's opposition to Motion for Summary Judgment: sexual harassment
  
• Bankruptcy -- relief from default judgment
  
• Opposition to motion to dismiss: sex discrimination
  
• Defendant's brief re broker liability; nondisclosure
  
• Legal malpractice: Opposition to demurrer
  
• Trial brief -- breach of contract; fraud
  
• Trial brief -- negligence per se
  
• Plaintiff's Opposition to motions in limine -- personal injury
  
• Plaintiff's Opposition to summary judgment -- personal injury
  
• Plaintiff's Opposition to summary judgment -- premises liability
  
• Plaintiff's Opposition to summary judgment -- age discrimination
  
• Plaintiff's Opposition to summary judgment -- sex discrimination
  
• Motion to suppress search and seizure -- drug case
  
• Summary judgment motion in section 1983 action
  
• Motion in limine -- sexual harassment case
  
• Defendant's trial brief re duty to warn -- premises liability
  

 

Briefs in appellate proceedings

• Appellant's opening brief re costs and fees in a contested probate proceeding
  
• Appellant's opening brief re priority of attorney's fee lien
  
• Appellant's opening brief re decedent's capacity to marry
  
• Appellant's opening brief re ruling issued after jurisdictional limit
  
• Appellant's opening brief re holographic will
  
• Respondent's brief re attorney's fees on appeal
  
• Respondent's brief: res judicata
  
• Respondent's brief on appeal re breach of contract
  
• Respondent's brief on appeal re municipal liability
  
• Petition to Cal. Supreme Court -- civil forfeiture
  
• Respondent's brief re attorneys' fees

RETURN TO TOP OF ARCHIVES PAGE

---

By subject matter

Administrative law

• Motion to compel production of documents - Nevada
  

Attorney's fees

• Appellant's opening brief re priority of attorney's fee lien
  

Bankruptcy

• Bankruptcy -- relief from default judgment
  

Civil procedure

• Drafting a complaint against a telephone company
  
• Opposition to motion to dismiss
  
• Appellant's opening brief re ruling issued after jurisdictional limit
  

Civil rights/Constitutional law

• Summary judgment motion in section 1983 action
  
• Attorney's fees and punitive damages in section 1983 action
  
• Petition to Cal. Supreme Court -- civil forfeiture
  

Commercial paper

• Plaintiff's mediation brief -- check-cashing fraud
  
• Memo re claim for payment of certificates of deposit
  

Contracts

• Memo re liquidated damages provision in North Carolina
  
• Failure to correct leaseholder's flooding problem negates contract
  
• Demurrer to complaint alleging fraud, negligence, breach of contract and breach of warranty against subcontractor
  
• Memo re proving lost profits
  
• Memo re prepayment penalty
  
• Respondent's brief on appeal re breach of contract
  
• Respondent's brief re attorney's fees on appeal
  

Corporations

• Memo re liability for failure to pay employment taxes
  

Criminal law

• Motion to suppress search and seizure -- drug case
  
• Defendant's Ps and As in support of motion to exclude evidence
  

Debtor and creditor

• Memo re unfair debt collection practices
  

Employment law

• Memo re Dept. of Labor jurisdiction re Fair Labor Standards Act
  
• Plaintiff's opposition to motion for summary judgment - sex discrimination
  
• Opposition to motion for summary adjudication - discrimination based on age, ancestry, and religion
  
• Plaintiff's opposition to Motion for Summary Judgment: Sexual harassment
  
• Opposition to motion to dismiss: sex discrimination
  
• Plaintiff's Opposition to summary judgment -- age discrimination
  
• Plaintiff's Opposition to summary judgment -- sex discrimination
  

Evidence

• Motion in limine to exclude expert's testimony
  

Family law

• Memo re community interest in restricted stock and unvested options
  
• Family law memorandum
  
• Respondent's brief: res judicata
  

Insurance

• Plaintiff's Points & Authorities in Opposition to Motion for Summary Judgment - insurer bad faith
  
• Insurance coverage; duty to settle; effect of bankruptcy on judgment
  
• Plaintiff's Motion for Summary Judgment & reply - insurer's duty to defend
  

Intellectual property

• Points & Authorities in support of motions to dismiss and strike - trademark issue
  

Municipal law

• Respondent's brief on appeal re municipal liability
  

Personal injury

• Opposition to demurrer - premises liability
  
• Memo re rental car co. insurance liability
  
• Memo re strict liability for chimp attack
  
• Memo re liability for wrongful death; strict liability
  
• Memo re personal injury; landowner liability
  
• Trial brief -- negligence per se
  
• Plaintiff's Opposition to motions in limine -- personal injury
  
• Plaintiff's Opposition to summary judgment -- personal injury
  
• Defendant's trial brief re duty to warn -- premises liability
  

Real property

• Memo re failure to build foundation according to specifications
  
• Memo re mall's liability for pit bull mauling
  
• Memo re broker's right to commission: lease/option
  
• Memo re lien sale of joint tenant's interest
  
• Memo re joint tenant's contribution to down payment
  
• Trial brief -- breach of contract; fraud
  
• Mediation brief -- failure to disclose defects in sale of real property
  
• Mediation brief -- failure to disclose offsite landfill in sale of real property
  
• Defendant's brief re broker liability; nondisclosure
  
• Memorandum re real property; leases; condemnation
  

Torts

• Legal malpractice: Opposition to demurrer
  
• Motion in limine -- sexual harassment case
  
• Memo re attorney's fiduciary duty
  
• Memo re store's liability for detaining employee on suspicion of theft
  
• Commercial landowner's liability for assault on patron
  

Unfair business practices

• Opposition to Demurrer - Plaintiff properly pleaded fraud and intentional infliction of emotional distress in sale of her business
  
• Memo re liability for taking a competitor's employees
  

Wills and probate

• Appellant's opening brief re costs and fees in a contested probate proceeding
  
• Memo re effect of amending a trust
  
• Memo re joint tenancy account and undue influence
  
• Appellant's opening brief re decedent's capacity to marry
  
• Appellant's opening brief re holographic will
  

RETURN TO TOP OF ARCHIVES PAGE

---