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Writing Samples

Petitions for Discretionary Review

Application for Discretionary Review Presented to the New York Court of Appeals on the Issue of what Constitutes a Sufficient Prima Facia Showing of Causation to Defeat Summary Judgment.

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Petition for Certiorari to the Supreme Court of the United States on the Issue of Whether a State Law Refusing to Recognize a Claim for Breach of Fiduciary Duty by Penitent against Religious Leader who disclosed the Penitent’s confidences violated the Establishment Clause of the United State Constitution.

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Petition for Discretionary Review to the Supreme Court of California Arising Out of Building Permit Dispute and Raising Issues Concerning the Doctrines of Independent Review and Collateral Estoppel.

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Petition for Discretionary Review to the Supreme Court of Texas Arising Out of Construction Litigation Involving Issues of Assignment of Claims and Prohibited Settlement Agreements Among Joint-Tortfeasors.

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Appellate Brief Bank

Appeal to New York's Highest Court Involving Issues of Municipal Liability and Qualified Immunity... (PDF)

Petition for Certiorari to the U.S. Supreme Court on the Issue of Whether a State Law ... violated the Establishment Clause of the U. S. Constitution. (PDF)