Trial Court Briefs
Strong trial-court briefing can decide a case before it ever reaches a jury. Motions to dismiss, Daubert challenges, and summary judgment arguments often determine whether plaintiffs get their day in court. This section collects samples of my trial-level writing. Some briefs are linked directly here; others, when tied closely to areas like medical malpractice or insurance bad faith, are listed with summaries and links to their full write-ups in those practice-area pillars. What unites them all is a focus on clear, forceful writing designed to persuade busy trial judges and frame the case for any appeal that follows.
Evasive Responses to Interrogatories: Piedmont Healthcare
Summary of Motion
In Crawford v. Piedmont Healthcare, we filed a motion to compel proper discovery responses. We asked two basic interrogatories: when the surgeon was called and when “Rapid Response” and “Code Blue” alerts were triggered. Piedmont replied only that it “does not maintain” the information, suggesting the hospital subsidiary “may” have it. Georgia law requires a party to provide all information “available to” it, including from subsidiaries or through reasonable inquiry. By refusing either to answer or confirm unavailability, Piedmont’s evasive response counts as no answer under OCGA 9-11-37.
Documents
Find a pdf of the filed brief here; full text of the brief here.
Frivolous Defense Expert to Block a Deposition
Summary of Brief
In Como v. Emory, Defendants asked the Court to block the deposition of Dr. Jason Bariteau, Chief of Foot and Ankle Surgery. We opposed, arguing Georgia law strongly favors broad discovery. Defendants provided no affidavit from Dr. Bariteau, no evidence of burden, and only lawyer assertions without personal knowledge. Georgia courts rarely prohibit depositions, and only with evidence of undue burden or oppression. OCGA § 9-11-26.1’s limited “apex” rule doesn’t apply here because Dr. Bariteau is not a corporate officer. Our response asks the Court to deny the motion and allow this routine, plainly relevant deposition to proceed.
Documents
Find a pdf of the filed brief here; full text of the brief here.