Utah Supreme Court
Amicus Brief in Petito v. City of Moab
An amicus brief challenging sovereign immunity under the Utah Constitution and arguing that constitutional remedies cannot be erased by later immunity doctrine.
Appellate briefs
Supreme Court of Georgia
Amicus Brief in Turner v. Medical Center of Central Georgia
An amicus brief arguing that Georgia’s wrongful-death damages cap is unconstitutional because it strips juries of their role and imposes unequal burdens on malpractice families.
Georgia Court of Appeals
Opening Appeal Brief in Perry v. Pearson
An appellant’s brief arguing that late filing of proof of service does not undo timely service or justify dismissal when the defendant was in fact served before the limitations period expired.
Georgia Court of Appeals
Opposition to Interlocutory Appeal in Edwards v. P.A.M. Transport
A response opposing an effort to halt discovery in a wrongful-death trucking case by invoking prospective Fifth Amendment issues as a basis for a blanket stay.
Trial-court briefs
State Court of Richmond County, Georgia
Motion to Compel Discovery Responses in Crawford v. Piedmont Healthcare
A motion to compel legally sufficient answers to core interrogatories after Piedmont responded only that it did not “maintain” the requested information instead of answering or confirming unavailability.
State Court of DeKalb County, Georgia
Response to Motion to Quash Deposition in Como v. Emory
A trial-court response opposing efforts to block the deposition of an Emory administrator, arguing that Georgia discovery law favors depositions absent evidence of undue burden or statutory protection.
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