Trial
Index
- Defendant's limine motion in employment cases in general (fed)
- Juror questionnaire for use by defendant in employment case (state and federal)
- Unopposed/opposed motion and brief for use of juror questionnaire (state & fed)
- Order granting use of juror questionnaire (state & fed)
- Direct Examination Outline: Defendant's H.R. Manager
- Direct examination outline: plaintiff's economist in employment (and personal injury) cases
- Trial brief: evidence of similar incidents is relevant and admissible
- Plaintiff's limine motion in employment cases in general (state)
- Defendant's limine motion for employment cases involving AGE/RACE (FED)
- Plaintiff's Jury Instructions and Jury Charge: Whistleblower Case (State Court)
- Defendant's Proposed Questions and Instructions to the Jury and Memorandum of Law: Age (Reduction In Force) and Race Discrimination Case (Federal Court)
- Defendant's proposed voir dire questions for judge in age, race & rif cases (fed & state)
- Defendant's Proposed Voir Dire: Age, Race (Fed.)
- Defendant's Trial Brief: F.I., Breach of Contract, Handbook, Mitigation
- Stipulation: Plaintiff's Damages
- Stipulation: plaintiff's reasonable & necessary attorney's fees
- Stipulation: corporation assumes liability, if any, for subsidiary or related companies in dispute involving current or former employee (state/federal)
- Direct: Treating Psychologist For Plaintiff
- Order on motion to strike witnesses and objections to fact witnesses (fed)
- Brief in support of motion to strike and objections to testimony of fact witnesses (FED)
- Motion to Strike Witnesses
- Juror Personal History Questionnaire
- Defendant's jury instructions & questions: sex discrimination, retaliation and FLSA violations (fed.)
- Sample Jury Charge-Non-Compete Case
- Defendant's requested jury instructions and written interrogatories
- Juror Questionnaire - Gender Discrimination and Breach of Contract
- Plaintiff's Jury Demand
- Plaintiff's Motion in Limine - Gender Discrimination Case - State Court
- Plaintiff's Requested Jury Instructions and Questions - Gender Discrimination and Breach of Contract