We handle strategic trial support, which includes the preparation and argument of dispositive motions in trial courts (e.g., motions to dismiss, Daubert motions, summary judgment motions, directed verdict motions, new trial motions, reconsideration motions, rehearing motions) and litigation support during trial (e.g., assistance with error preservation, jury instructions, and verdict forms).

Our sample motions include:

Objections to magistrate’s report and recommendation in United States v. Farha, No. 8:11-cr-00115 (M.D. Fla.) (whether defendants in massive white collar prosecution could subpoena company’s internal investigation materials, including drafts);

Response in opposition to motion to vacate in BB&T v. Pair A Dice, No. 8:10-cv-00291 (M.D. Fla.) (whether to vacate default judgment);

Response in opposition to summary judgment motion in Charles v. Frank, No. 2004-cv-2853 (Wis. Cir. Ct.) (whether Religious Land Use and Institutionalized Persons Act, Free Exercise Clause, or Equal Protection Clause allowed prison to force Muslim inmates who desired a halal diet to eat a vegetarian diet instead of offering them a kosher diet, which it would give only to Jewish inmates);

Motion for reconsideration in Fentriss v. Gateway Bank, FSB, No. 8:15-cv-2675 (M.D. Fla.) (whether to reconsider dismissal of statutory securities fraud claim);

Memorandum in support of motion to exclude expert and response in opposition to motion to exclude expert in Town of Lexington v. Pharmacia Corp., No. 1:12-cv-11645 (D. Mass.) (toxic tort);

Motion for indicative ruling whether to vacate the judgment in Moore v. Intuitive Surgical, Inc., No. 1:15-cv-56 (M.D. Ga.) (whether to vacate judgment in light of district judge’s failure to recuse despite her husband’s financial interest in the defendant in a medical device litigation); 

Response in opposition to motion to strike jury trial demand in Walter v. Sunrise, No. 13-CA-9015 (Fla. 13th Cir. Ct.) (enforceability of jury trial waiver clause).