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When you assign a project to Lawyers’ Legal Research and Writing, you will receive documents that are complete, concise and compelling. Some examples of my briefs, pleadings and memoranda appear below. To protect the privacy of those involved, the names and certain other identifying information have been changed.
Opposition to Petition for Certiorari, Supreme Court of the United States.
Brief in Opposition to Petition for Certiorari, arguing that the Court of Appeals for the First Circuit had correctly applied the Parratt-Hudson Doctrine to bar the plaintiff Assistant Deputy Superintendant’s political discrimination procedural due process claim arising from termination of his employment after he had supported unsuccessful candidate in election for County Sheriff.
Appellate Brief, Massachusetts Appeals Court.
Brief of appellee, arguing that appellants had not acquired an easement by prescription, easement by necessity or easement by implication to use pathway crossing appellees’ house lot.
Appellate Brief, Massachusetts Appeals Court.
Brief of appellee, arguing that lower courts had correctly held that appellee was not liable as personal guarantor of corporate lease because his signature on guaranty had been obtained by fraud in the factum or due to unilateral mistake. The brief also asserted that the corporate lessee was not liable on the underlying debt because, among other things, the liquidated damages provision of the lease was an unenforceable penalty.
Opposition to Motion for Summary Judgment, Massachusetts Superior Court.
Opposing homeowner’s motion for summary judgment on personal injury claims of plaintiffs, employees of an independent contractor hired by homeowner to construct home, who were injured when scaffolding collapsed. The critical issue was whether the Court should apply the general rule, absolving a property owner who hires an independent contractor of liability for worksite injuries, or an exception to that rule, based on the owner’s retained control over the job.
Opposition to Motion for Summary Judgment, Massachusetts Superior Court.
Opposing insurance company’s motion for summary judgment, which argued that its insured was not responsible for injuries suffered by the plaintiff, a social guest at the insured’s condominium, when plaintiff was attacked by the insured’s former boyfriend.
Opposition to Motion for Summary Judgment, Massachusetts Superior Court.
Opposing corporate employer’s motion for summary judgment in personal injury action arising from auto accident between corporate employee and plaintiff, caused by employee’s negligence. The primary issue was whether the employee was acting within the scope of employment when the accident occurred as he was driving home from work but arguably was still on the employer’s premises.
Motion for Summary Judgment, United States Bankruptcy Court, District of Massachusetts.
Motion of mortgagee for summary judgment on various common law and statutory claims raised by mortgagors in effort to avoid foreclosure of residential property.
Motion to Dismiss, United States District Court for the District of Massachusetts.
Motion to dismiss claims of borrower against lender, arising from foreclosure sale. The lender argued that the claims were barred by res judicata (claim preclusion) and failed to state claims upon which relief could be granted.
Opposition to Motion in Limine, Massachusetts Superior Court.
Plaintiff’s opposition to defendant’s motion in limine to exclude from products liability action evidence of subsequent remedial measures offered to prove feasibility of safer design.
Office Memorandum.
Internal memorandum regarding whether water and sewer pipes crossing landowner’s property are de minimis encroachments such that court can exercise equitable powers to allow owner of pipes to continue using the pipes even in the absence of a prescriptive easement.
Article.
A published article regarding false advertising claims under federal and Massachusetts law, as published in the Massachusetts Academy of Trial Attorneys Journal (November 2011)
