Writing Samples

Appeal to New Yorks Highest Court Involving Issues of Municipal Liability and Qualified Immunity Concerning Injuries Sustained due to Traffic Hazards.

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Summary Judgment Appeal Involving Federal Pre-Emption of State Law Consumer Protection and Contract Claims Against Large Wireless Telephone Service Provider Presented to the Dallas Court of Appeals.

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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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Research Memorandum Analyzing Potential Summary Judgment Motion by City Seeking Dismissal of Federal Civil Rights Claim Against Police Office Focusing Primarily on 9th Circuit Jurisprudence
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California Trial Court Opposition to Demurrer Filed by Insurance Company Seeking Dismissal of Claim Arising Out of Dog Fighting Incident.
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Case Evaluation Analyzing Potential Claims for Unjust Enrichment, Breach of Fiduciary Duty, and Breach of Good Faith and Fair Dealing Under New York Law.
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Article Drafted for Publication in Legal Journal Discussing the Doctrine of Caveat Emptor Under New York Law.
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