Manage wrongful death, catastrophic injury, premises liability, products liability, and other complex casualty matters across numerous industries in both Texas and federal courts
Draft complex written motions including motions to exclude or limit expert testimony, motions for summary judgment, motions for protection, and responsive motion practice
Comprehensively draft pre-trial and trial documents including motions in limine, exhibit lists, witness lists, deposition designations, opening and closing statements and presentations, witness direct and cross-examination outlines, and proposed jury charges and instructions
Negotiated favorable resolution of matters in multi-party mediations
Independently argued multi-day pre-trial hearing including for exclusion of certain evidence and testimony at trial with complete defense verdict outcome