Litigation & Trial Preparation: conducting research for / drafting and preparing initial motions / responses, propounding discovery and responses: Complaints, Answers, Request for Admissions (RFA), Interrogatories (Rogs), Requests to Produce (RTP), Motions to Compel (MTC), Motions for Protective Order (MPO), Motions for In-Camera Inspection, Motions for Extension of Time (MET), Motion for Sanctions, Motions to Consolidate, Motions to Transfer Venue, Motions to Dismiss (MTD), Motions for Default, Requests for Assistance, Petitions for Benefits / Claims for Benefits. Specialty in M/ Att. Fees & Costs, Att. Fee Affidavit, & Timesheet maintenance. issuing Notice of Production Non-Party (NPNP) and Subpoena Duces Tecum (DT); summarization / page & lines of Examinations Under Oath (EUO) and deposition transcripts
