Here are a few samples of my written work product:

1. Opposition to Demurrer

Jurisdiction:	California - Orange County Superior Court
Filed:	November 18, 2011
Description:	As one of the few California-licensed litigators at Polsinelli Shughart, I was called upon to help represent a major client, a health system based in Orange County, California. This document is from a case in which Mission Hospital, one of the hospitals in the system, was seeking possession of a medical/surgical suite from a surgeon who was approximately $60,000 behind in his rent. The surgeon's attorney filed a demurrer (essentially, a motion to dismiss) in response to Mission Hospital's complaint. I prepared the written opposition to that demurrer and appeared, personally, in Orange County Superior Court to argue against the demurrer. The demurrer was sustained (by a substitute judge) on one ground, that the process server's affidavit, prepared and filed by the process server, did not list the "place of signing." As a result, Mission filed an amended complaint, including a revised affidavit from the process server. In response to the amended complaint, the defendant filed yet another demurrer. This document is the opposition to that demurrer. Again I prepared the written opposition and appeared, personally, in Orange County Superior Court for the oral argument on the demurrer. This time, with our assigned judge presiding over the hearing, the demurrer was overruled in its entirety. I prepared both of the oppositions in this matter, and argued at the hearings on each, with minimal supervision from the senior attorneys. No changes, whatsoever, were made to this document by anyone.

2. Motion to Dismiss

Jurisdiction:	Illinois - Circuit Court of Cook County
Filed:	November 9, 2011
Description:	I prepared this motion on behalf of a bank client that was being sued by a borrower who had second thoughts after a deed-in-lieu tansaction. The bank sued for possession of the property, and was then sued itself when the borrower filed a complaint to quiet title. This was the second motion to dismiss filed in this case. I also prepared the first motion, and argued it as well. That motion was granted and the court allowed the borrower to amend its complaint. This motion is the response to the amended complaint. I prepared the arguments, research, and other substantive elements of this document. This motion was reviewed and slightly edited by a supervising attorney, primarily for stylistic changes.

3. Emergency Motion for Appointment of a Receiver

Jurisdiction:	Illinois - Circuit Court of Cook County
Filed:	May 26, 2011
Description:	On a Thursday afternoon, just before the Memorial Day weekend, I received a call from a client, informing me that a multi-unit residential apartment building, currently in foreclosure, had just had its gas service shut off by the utility. This was a foreclosure that was headed toward a deed-in-lieu or a short sale, and until this event there had been a property manager on site and no real need to have a receiver appointed. Within three hours I prepared this emergency motion (as well as all of the affidavits, exhibits, and notices), coordinated with the receiver, and was able to get the assigned judge to hear the motion the next morning. The motion was granted, the receiver was appointed, and the gas service was turned back on. While this document was built off of an existing firm template which included most of the case law and general arguments in favor of the appointment of a receiver, this document and the story behind it is, I believe, a testament to my skills at being able to react to a crisis situation. Both the client and the receiver were amazed at how quickly this was turned around, and that we were able to get the receiver in place less than 24 hours after the crisis arose.