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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 Judgments

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 more dangerous, well-drawn motions, saving your case for another day.

To prepare an opposition for you, we'll need the complaint and answer, the moving papers, the complete transcripts of any deposition 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.

Appellate briefs

We write appellate briefs in both state and federal courts.

We've worked on appeals from weeks-long trials, from case-dispositive motions, and from post-judgment matters.

In some cases, we may suggest that you first authorize a limited amount of preliminary research so that the research attorney can assess the issues on appeal and discuss with you the likely outcome. We'll give you our honest opinion of your chances of success. You'll then have something on which to base your decision about whether to go forward with the appeal.

Extraordinary writ petitions

We also draft writ petitions, including petitions for review in the California Supreme Court. For the most part, we discourage writ petitions because the courts grant so few of them that the risk/reward ratio tilts toward risk.

One year we had three writ petitions granted, a personal best, but that kind of success is rare. Still, if you do have that unusual case where the lower court's ruling is just plainly wrong, we'll write you the tightest, most sharply pointed writ petition we can. We just can't guarantee success, even if you have a strong case.

Take a look at some documents we've written. »