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Trial & Appellate Writing samples

 
Supreme Court Election Litigation - Opposition to Emergency Petition for Writ of Mandamus
IN RE: JUAN GERARDO PEREZ PICHARDO AND PUBLIC INTEREST LEGAL FOUNDATION, INC.
Defended Harris County Voter Registrar to eleventh-hour challenge to voter records.
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COVID-19 Litigation - Opposition to Temporary Restraining Order
Steven Hotze, et al. v. Harris County Judge Lina Hidalgo and Harris County, No. 2020-22609, 281st District, Harris County, Texas. 
Defended Harris County's COVID-19 regulations promoting remote ministering by churches and the practice of social distancing and hygienic conditions during in-person services.
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Texas Supreme Court - Brief on sovereign immunity/Texas Tort Claims Act.
Annab v. Harris County, 547 S.W.3d 609 (Tex., 2018)
Supreme Court granted petition for review and reversed lower court by 9-0 decision. The ruling interpreted the scope of the Texas Tort Claims Act after an off-duty deputy constable shot a woman in a fit of road rage. Gave oral argument with Texas Solicitor General.
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Louisiana Supreme Court on behalf of disabled college students.
Covington v. McNeese, 98 So.3d 414 (La.App. 3 Cir. 9/5/12)
Secured $13.8 million injunction and systemic changes at eight Louisiana universities under the Americans with Disabilities Act. Court of Appeals awarded attorney's fees of approximately $2 million, reduced by Supreme Court to approximately $1.5 million. Gave three appellate oral arguments during this 12-year case. 
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Federal Fifth Circuit Court of Appeals - Defense of Employment case.
Otis Grant v. Harris County (5th Cir., 2019)
Prevailed on summary judgment and defended appeal. Oral argument scheduled August, 2019.  
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Federal Civil Rights on behalf of wrongfully incarcerated person.
Rickey Dale Wyatt v. City of Dallas, et al. (Northern District of Texas, 2014)
Received compensation for client under the Tim Cole Act. Total recovery was approximately $2.5 million cash and approximately $2.5 million annuity. 
 
Federal Civil Rights - Defense of Sheriff after inmate died of bacterial meningitis.
Green v. Harris County, Texas (Southern District of Texas, 2019)
Motion for Summary Judgment granted. Case dismissed and costs awarded. 
 
University of Houston litigation over Hofheinz Pavillion. (Breach of Contract/Trust).
In Re: Hofheinz Charitable Trust (Harris County, Texas, 2016) 
Suit to require the University of Houston to honor terms of naming agreement for athletic facility. Case settled. 
 
Summary judgment in legal malpractice case.
Lindsay General v. Nguyen (Cameron County, Texas, 2014)
Prevailed in summary judgment in Cameron County, Texas.
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