Range of Services

I. Pretrial services:

• Consult on litigation strategy
• Prepare pleadings
• Research, prepare and argue complex motions, such as motions for summary judgment and responses to motions for summary judgment, motions to transfer venue, motions to remand, and so forth
• Consult on discovery problem
• Research and prepare jury questions
• Research, prepare and argue petitions for writ of mandamus to the court of appeals to complain of trial court error
• Research, prepare and argue interlocutory appeal (on issues such as the appointment of a receiver, class certification, temporary injunction, government immunity, a government's plea to the jurisdiction, grant or denial of special appearance, etc.)
• Research, prepare and argue Dauber/Robinson issues
• Consult on alternative dispute resolution, such as mediation, arbitration or summary trial
  

II. Trial services:

• Research, prepare and argue motions in limine
• Second chair trial to ensure preservation of error for appeal
• Consult on objections to evidence and witnesses
• Prepare and present jury charge
• Research and prepare trial briefs on complex topics
• Consult on trial strategy
• Prepare and present examination of difficult witnesses
• Prepare and present argument to the jury
• Consult on settlement strategy
  

III. Post-trial services:

• Research and prepare judgment
• Research, prepare and argue post-trial motions, such as motion for new trial, motion for judgment notwithstanding the verdict, motion to correct, modify or reform the judgment, motion to alter and amend the judgment, motion for reconsideration, and so forth
• Consult on post-trial settlement options
• Prepare appellate timetable
  

IV. Appeal services:

• Prepare notice of appeal
• Consult on supersedes bond or other security
• Prepare request for appellate record
• Consult with trial lawyers about issues to rise on appeal
• Consult with trial lawyers and client about settlement while case is on appeal
• Review and digest record in preparation for appellate brief
• Act as "final pen" in research and preparation of appellate briefs
• Prepare and present oral argument to court of appeals
• Research and prepare motion for rehearing
• Prepare petition for review to Supreme Court of Texas, or petition for writ of certiorari to the Supreme Court of the United States
• Research and prepare brief on merits
• Prepare for and present oral argument to high court
• Consult on collection of judgment