Texas Employment Law. Volume 2 - 2016
- Special Exception and Answer (State Court)
- Letter to Individual Defendant Regarding Joint Representation Agreement
- Preliminary Sections
- Stipulation: Corporation Assumes Liability for Subsidiary or Related Companies (State/Fed.)
- Final Closing Letter to Plaintiff Client
- Plaintiff's Original Petition - Sabine Pilot/Refusal to Perform Illegal Act
- FMLA2006-5-A
- Plaintiff's Response to Defendant Employer's Motion for Summary Judgment - Workers' Compensation Retaliation Case
- FMLA Opinion Letters
- Defendant's Jury Instructions and Questions: Sex Discrimination, Retaliation and FLSA Violations (Fed.)
- Discovery Plan (Worksheet)
- Military Records Authorization
- Employment Case Intake Questionnaire
- Table of cases
- Plaintiff's Proposed Pattern Interrogatories and Request for Production
- FMLA2006-1-A
- Federal and Texas Labor and Employment Recordkeeping Requirement
- Letter to Dual Clients Concerning Joint Representation Agreement
- New Client Information Sheet
- Index
- Response to EEOC Charge of Discrimination
- Oral and Video Deposition Duces Tecum Propounded to Defendant for Employment Cases in General
- Motion to Strike Witnesses
- Joint Proposal for Contents of Scheduling Order
- Taking the Case
- Plaintiff's "Triple Threat" Discovery to Former Employee Stealing Trade Secrets
- Checklist: Documents for Initial Meeting with Prospective Client
- Sarbanes-Oxley-Compliant Whistleblower Policy
- Confidentiality and Nondisclosure Agreement
- Authorization for Texas Worker’s Compensation Commission Records
- Unopposed Motion to Expe 5th Circuit Appeal
- Sample Employment Agreement for an Account Executive or Sales Employee
- Discrimination Based on National Origin, Religion, and Other Grounds
- Standard Instructions and Definitions for Defendant’s Written Discovery to Plaintiff
- Defendant's Proposed Voir Dire: Age, Race (Fed.)
- Level Three Discovery Control Plan
- Power of Attorney Coupled with an Interest
- Motion for Summary Judgment (by Employer) for False Imprisonment and Breach of Contract
- Memo Detailing Procedures for Fair and Thorough Investigation of Alleged Discrimination, Harassment and/or Retaliation
- Race Discrimination
- Whistleblower Protection Under Sarbanes-Oxley
- Defendant's "Triple Threat" Discovery Propounded to Plaintiff Employee's Spouse
- Letter Firing Employee
- Plaintiff's Jury Instructions and Jury Charge: Whistleblower Case (State Court)
- Plaintiff's Motion in Limine for Employment Cases in General
- Certification of Health Provider (DOL Form)
- Medical records authorization
- Defendant's Requested Jury Instructions and Written Interrogatories
- Pre-Employment Inquiries
- Affidavit - Authentication of Deposition Excerpts
- Plaintiff's Petition - Workers' Compensation Retaliation
- Affidavit - Discovery Authentication
- Defendant's Proposed Voir Dire Questions for Judge: Age, Race, RIF Cases
- Sample Employment Agreement for an Executive Employee
- Affidavit - Business Records
- Standard Responses, Objections, and Answers to Interrogatories For Defendants and Plaintiffs
- Unopposed/Opposed Motion and Brief for Use of Jury Questionnaire
- Deposition Duces Tecum Propounded to Defendant City, Whistleblower Case
- Internal Complaint Review Procedure
- Employment Records Authorization
- Standard Responses, Objections and Answers to Request for Production of Documents for Defendants and Plaintiffs Under Texas Rules of Civil Procedure
- Defendant's "Triple Threat" Discovery to Plaintiff - Sexual Harassment and Firing
- Texas Whistleblower Act
- Request for Disclosures (Long Form) (State)
- Joinder in/Consent to Removal
- Defendant's Standard Brief in Support of Motion to Compel Arbitration, Dismiss and Stay Proceedings (State Court)
- Demand Letter: FLSA Overtime Case
- Supervisor Sexual Harassment Roadmap
- Plaintiff's Brief in Support of Motion for Summary Judgment - ADEA - Federal Court
- Affirmative Action Obligations for Government Contractors
- Defendant's Motion to Dismiss for Lack of Subject Matter Jurisdiction and Supporting Brief - Title VII - Federal Court
- Direct Examination Outline: Defendant's H.R. Manager
- Schedule to Associate Physician Employment Agreement
- Plaintiff's "Triple Threat" Discovery to Defendant in Age Discrimination Case
- Request for Disclosures (Short Form) (State)
- Request For Disclosure To Defendant-FMLA, ADEA
- Stipulation: Plaintiff's Damages
- Noncompetition, Nondisclosure of Confidential Information, Nonsolicitation Agreement
- Discovery
- Deposition Outline - Economist
- Motion to Compel Arbitration, Dismiss, and Stay (State Court)
- Plaintiff's Jury Demand
- Stipulation: Plaintiff's Reasonable and Necessary Attorney's Fees
- Opposition to Motion to Vacate Arbitration Award; Motion and Brief to Confirm Arbitration Award
- Sarbanes-Oxley-Compliant Employer Posting
- Scholastic Records Authorization
- Plaintiff's Original Petition-FMLA, ADEA
- Order on Motion to Strike Witnesses and Objections to Fact Witnesses (Fed.)
- Reserved
- Brief in Support of Motion to Strike and Objections to Fact Witnesses (Fed.)
- Deposition Outline - Medical/Mental Health Professional
- Comparison of State and Federal Summary Judgment Procedure
- Defendant's Standard Brief in Support of Motion to Stay Pending Arbitration (Federal Court)
- Motion to Compel Discovery (State)
- FMLA2006-6-A
- Consolidation Motion (Fed)
- Defendant's "Triple Threat" Discovery to Plaintiff - Race, Age & Firing
- Defendants' Motion in Limine: Age/Race Discrimination (Federal Court)
- Ethical Dilemmas
- Motion to Stay Pending Arbitration, Alternatively Motion to Dismiss (Federal Court)
- Plaintiff's "Triple Threat" Discovery to Defendant - Sex Discrimination (State Court)
- Non-Compete Agreement
- Authorization for Release of Financial Records
- Defamation in the Workplace
- Employer Response to Employee Request for FMLA Leave (DOL Form)
- Deposition Outline - Corporate Representative - Products Liability
- Pattern Interview of Employee Accused of Discrimination/Harassment/Retaliation
- Settlement Agreement and Release (Includes OWBPA Language)
- Direct Examination Outline: Plaintiff's Economist in Employment (and P.I. Cases)
- Sample Jury Charge-Non-Compete Case
- Opposition to Pre-Suit Deposition
- Order Granting Use of Jury Questionnaire
- Outline for Advising Employee Negotiating a Severance Package
- Retainer Agreement: Contingent Percentage with No Assignment
- Reserved
- Plaintiff's Motion to Dismiss Pursuant to Settlement
- Plaintiff's Trial Brief: Evidence of Similar Incidents Is Relevant and Admissible
- WHD Side by Side Comparison/Final Regulations 2008-2013
- Defendant's Jury Questionnaire
- Deposition Checklist: Deposing the Plaintiff in Employment Cases (In General)
- Retainer Letter: Representation of Defendant in Employment Law Matter
- Notice Letter: Preserve Evidence in a Commercial/Employment Case
- Plaintiff's Motion in Limine - Gender Discrimination Case - State Court
- FMLA2006-4-A
- Deposition Outline Checklist: Plaintiff’s Deposition of Defendant’s Employees: General Questions
- Retainer Letter: Representation of Executive on Hourly Basis
- Emergency Motion for Temporary Stay Pending Appeal to 5th Circuit
- Letter Requesting More Information Before Taking Case - Employment
- Retainer: Including a Joint Representation Agreement
- Plaintiff's Petition - Employment Agreement - Fraud
- Privacy Issues in the Workplace
- Letter: Demand on Plaintiff to Go to Arbitration
- Plaintiff's Triple-Threat to Defendant re: Stealing Trade Secrets
- Suggestions to Client re: Filing EEOC/TCHR Charge of Discrimination
- Pattern Interview of Possible Witnesses to Alleged Discrimination/Harassment
- Defendant's First Set of Requests for Production to Plaintiff-FLSA
- Petition to Compel Arbitration (State Court)
- Discrimination Claims Under Labor Code Chapter 451
- Protection of Business Interests
- Juror Personal History Questionnaire
- Reserved
- Plaintiff's Letter Brief - Gender Discrimination - Cat's Paw Doctrine
- Defendant's Trial Brief: F.I., Breach of Contract, Handbook, Mitigation
- Order Granting Objections to Summary Judgment Evidence
- "About Your Upcoming Deposition"
- Sworn Statement by Non-Managerial Employee of Defendant
- Telephone Interview Checklist - Prospective Client - Employee
- Order Authorizing Deposition
- Plaintiff's Requested Jury Instructions and Questions - Gender Discrimination and Breach of Contract
- Summary Judgment Evidence
- Plaintiff's Original Petition
- FOIA Request to the EEOC
- Petition Requesting Deposition Before Suit
- General Complete Release in Favor of Defendant (With Mutuality Option)
- Release and Severance Agreement (OWBPA Agreement)
- Family and Medical Leave Act
- Oral and Video Deposition Duces Tecum to Plaintiff for Employment Cases in General
- FMLA2006-3-A
- Defendant's Proposed Questions and Instructions to the Jury and Memorandum of Law: Age (Reduction In Force) and Race Discrimination Case (Federal Court)
- Juror Questionnaire - Gender Discrimination and Breach of Contract
- Sample Release & Severance Agrmnt (Non-OWBPA Agrmnt)
- Letter to Plaintiff Declining Representation
- Letter to Plaintiff Declining Representation - Alternate
- Introductory Letter to Plaintiff in an Employment Case
- Amended Complaint - TCHRA - Age Discrimination
- Defendant's Limine Motion in Employment Cases in General (Fed.)
- Plaintiff's "Triple Threat" Discovery Propounded to Defendant in Sexual Harassment Case
- Defendant's "Triple Threat" Discovery Propounded to Plaintiff in Employment Cases in General
- Plaintiff's First Request for Production of Documents Propounded to Defendant City in a Whistleblower Case
- Summary Judgment Practice
- Telephone Interview Checklist - Prospective Client - Employer
- Open Records Request to the TCHR
- Initial Letter to Defendant's Supervisor
- Other Workplace Torts
- Brief for Emergency Motion for Temporary Stay
- Defendant's Motion for Summary Judgment: After-Acquired Evidence, Wrongful Discharge, Constructive Discharge, IIED, Retaliation, Whistleblowing
- Standard Responses, Objections, and Answers to Interrogatories for Defendants and Plaintiffs Under Texas Rules of Civil Procedure
- Order of Dismissal
- Retaliation
- Separation and Release Agreement (For Unrepresented Employee)
- Demand Letter: Employment Cases in General
- Direct: Treating Psychologist For Plaintiff
- Standard Responses, Objections, and Answers to Request for Production of Documents for Both Defendants and Plaintiffs
- Defendant's First Set of Interrogatories to Plaintiff-FLSA
- Deposition Outline (Plaintiff) - False Imprisonment
- Pattern Interview of Employee Complaining of Discrimination/Harassment/ Retaliation
- Brief Supporting Motion to Expe Appeal
- Notice of Intent to Use Discovery Products
- Retainer Agreement: Options for Inclusion
- Defendant's Motion for Summary Judgment: Mitigation of Damages
- Standard Instructions and Definitions for Plaintiff's Written Discovery to Defendant
- Defendant's Plea to Jurisdiction
- Plaintiff's Standard "Triple Threat" Discovery to Defendant in Employment Cases in General
- Letter Seeking Information and Documents from Employers of Employee Subject to Your Client's Non-Compete Agreement
- Age Discrimination