Some Examples of Repeat Business

Last Updated July 2024

For a Los Angeles litigation boutique: Ninth Circuit brief on commercial / corporate issues — leading to second project — another Ninth Circuit brief in a separate matter.

For a Southern California small firm: Demurrer on complex transactional issues (jurisdiction, res judicata, collateral estoppel) — leading to additional briefing projects on separate matters. Also began serving as sounding board for subsequent mediations.

For a New York City partner at a small qui tam boutique: Most recent repeat business — fifth project — this time drafting a federal false claims act complaint with complex causation and damages issues.

For a San Francisco complex litigation and class action firm: Multiple brief writing assignments during state court litigation (motions for judgment on the pleadings, motion for decertification of class, more). On call as sounding board as case moves forward.

For a Los Angeles former prosecutor: Two California state court appeals in separate matters (business litigation).

For a New York City / Manhattan IP solo practitioner: Most recent repeat business — third project — this time preparing a draft brief on trademark and copyright issues in the fashion industry / market for mediation and related negotiations.

For an Orange County California small firm: Most recent repeat business — seventh project — this time drafting a motion to transfer venue.

For a Palo Alto / Silicon Valley small law firm: Appeal in California state court (commercial litigation) leading to demurrer and motion to strike (financial and IP litigation) on new matter. Sounding board re case strategies as the intellectual property case moved forward.

For a Los Angeles midsize law firm:  Successful summary judgment opposition brief in California state court (tort claims) — leading to additional business — a second successful MSJ opposition brief (strict liability). Ongoing periodic independent contractor relationship for briefing. Also asked to advise on case strategies, oral argument prep, and Writs (personal injury / causation).

For a metro New York City law firm:  Successful motion to compel in Federal District Court for a qui tam action (Chicago). Repeat work: Draft complaints in Federal District Court for two more whistleblower / False Claims Act actions (Philadelphia). More repeat work: Second motion to compel in Federal District Court (Seattle) for another fraud action. Five additional repeat projects; more repeat work pending.

For a San Francisco / Bay Area small law firm: Successful summary judgment opposition motion (soft IP / trade secrets / copyright) in Federal District Court.

For a Los Angeles midsize law firm: Successful opposition brief in response to motion for summary judgment (commercial real estate claims) in California state court. Repeat work: Second successful MSJ opposition brief (fraud, financial claims). Three additional repeat matters to date; additional repeat work pending.

For a New York City / Manhattan midsize law firm: Draft sections of brief in response to motion for summary judgment in multiparty complex litigation matter (federal statutory claims) in Federal District Court (SDNY). Subsequent work was scheduled then matter resolved.

For a Los Angeles midsize law firm: Opposition brief in response to motion for summary judgment (Fourth Amendment) in Federal District Court (Oregon). Subsequent projects were scheduled then matter resolved.

For a San Francisco / Bay Area midsize law firm: Complex discovery motion with multiple issues under the Federal Rules of Civil Procedure in Federal District Court for mass tort class action (San Diego); pending additional project became moot.

For a Los Angeles / Orange County midsize law firm:  Case strategy / consulting and expert witness analyses for matters in Arizona state court and Washington, D.C. (business reputation / defamation and related financial claims with multiple experts). Four separate projects then matter resolved.

For a Manhattan / New York City environmental boutique law firm: Draft sections of opposition Rule 12(b)(6) motion to dismiss in Federal District Court (New Jersey). Planned additional projects became unnecessary during motions practice.

For a Philadelphia law firm: Federal motion to dismiss under statue of limitations, Rule 9(b), and proximate cause grounds for multiple RICO claims and common law fraud, contract claims including breach of fiduciary duty and breach of the covenant of good faith and fair dealing. Subsequent additional projects became moot.

For a Las Vegas litigation boutique: Rule 12(b)(6) opposition brief (Section 1983 / Bivens / FTCA claims) in Federal District Court (Nevada); multiple repeat briefing projects.

For a Maine small law firm:  Opposition brief in response to motion for summary judgment in Federal District Court (Constitutional law / Fourth Amendment issues); subsequent repeat work.

For a Detroit, Michigan solo practitioner:  Opposition brief in response to MSJ (commercial and financial litigation) in Federal District Court (Miami / Florida); subsequent repeat work (briefing contract law issues).

For a Maine small law firm:  Administrative appeal in Federal District Court (Massachusetts); assist counsel with oral argument prep. Repeat work: Second administrative appeal in another matter.

For a Silicon Valley business / commercial litigation boutique for startups: Multiple repeat work assignments over time including (1) draft first amended complaint (FAC), (2) draft brief in support of motion to stay, and (3) drat successful oppositions to both a demurrer and a motion to strike punitive damages and related causes of action.

For a Hollywood / Los Angeles / Southern California law firm: Multiple projects on multiple matters including (1) successful defense of two demurrers and two motions to strike as to defamation, slander, and libel claims and related actual damages, special damages, and punitive damages claims; related questions of first impression under per se and per quod defamation law in California.

For a Maine small law firm: Refined and polished brief in support of motion for preliminary injunction to improve clarity of fact section and improve persuasiveness and credibility of argument section; additional scheduled work not needed because matter settled.

For a Bay Area / Oakland small law firm: Opposition brief in response to motion for summary judgment pursuant to Federal Rule of Civil Procedure 56 with multiple admissibility issues under the Federal Rules of Evidence (FRE); further work scheduled but matter resolved.

For a Southern California Firm — draft two complaints with causes of action including California’s unfair competition law (UCL) under Business and Professions Code Section 17200 and under California’s Consumer Legal Remedies Act (CLRA) regarding false and deceptive advertising; repeat business included opposing demurrers re same.