What BKG,PC Does

  Appellate Briefs   

Kathleen has years of experience prepared opening, response and reply briefs for general and special action appeals.  She also has experience with petitions for review to the Supreme Court, as well as various motions in the appeal court system.

   Complaints/Answers/Counterclaims/Crossclaims   

Kathleen has prepared simple complaints, answers and counterclaims as well as complicated multi-count complaints for  such matters as, inter alia, breach  of contract, breach of warranty, fraud, negligent misrepresentation, fraudulent  transfer, security fraud, punitive damages, unlawful acts and pattern of  unlawful activities, strict liability, injunctive relief, declaratory judgment,  alter ego liability, unjust enrichment and constructive trust.

   Discovery   

Kathleen has drafted requests  for admissions, requests for production of documents and uniform and  non-uniform interrogatories.  She has  also prepared detailed responses to each type of discovery request.

   Disclosure   

Kathleen has prepared various  types of disclosure statements, from the very simple to the complicated, including  detailed factual discussions of complicated issues.

  All types of Motions/Responses/Replies

Kathleen has prepared and  responded to all types of dispositive motions and other types of motions  including, inter alia, motion for  summary judgment, motion to dismiss, motion to strike, motion for more definite  statement, Rule 56(g) motion, motion to amend, motion for new trial,  application for default judgment, motion for protective order, motion to  vacate, motion for sanctions, motion to compel, motion to set aside default,  motion to increase bond, motion to continue, motion to exclude, motion to  intervene, motion to consolidate, motion for expedited hearing, motion for  separate trial on issues, and motion for nunc  pro tunc.

   Editing   

It is difficult to edit your own work and the task can be very time consuming.  Kathleen has experience editing the written  work product of other attorneys.

   Legal Research, Analysis and Memorandums   

Kathleen has vast experience  in conducting legal research on multiple legal topics and issues.  Research can be presented to you in a variety  of ways based on personal preference and/or case needs including merely case  law with highlights, brief research note quoting key language in relevant cases  or full legal memorandum with case analysis and discussion of law to facts.

   Letter Drafting   

Kathleen has experience  preparing various types of letters including, inter alia, status letters to clients, demand letters to opposing  counsel or defendants, inadequate answer and request to amend letters, insufficient disclosure letters and insufficient discovery response letters.

   Brainstorming

Given her extensive background and experience, Kathleen is able to assist her clients in brainstorming case strategies, arguments, and assist in the overall direction a case should take. 

   Second Level Reviews

A second pair of eyes is always helpful in preparing detail legal briefs and arguments. Kathleen has experience in providing second level reviews to help her clients pinpoint issues of concern and/or strengths and ensure a clean, well-written, persuasive brief.

   Trial Preparation

Trial preparation is always time consuming. Kathleen has experience in reviewing deposition to identify key information, preparing deposition summaries and outlines. She also has experience in identifying key exhibits and issues, preparing jury instructions, etc.

   Transactional Work

Kathleen has extensive experience in transactional matters including, inter alia, drafting and reviewing contracts, undertaking due diligence investigations, business entity formation, preparing non-compete and/or non-disclosure documents, asset purchase agreements, employee handbooks, etc. 

   Document Preparation

Kathleen has experience creating many specialty documents including, inter alia, continuing legal education materials, change of firm affiliation notices, and legal articles.

   Pre and Post Trial Motions and Memorandums   

Kathleen has experience in  preparing many types of pre and post trial motions and memorandums including, inter alia, motions in limine, proposed jury instructions, joint pretrial statement,  pretrial conference memorandum, remittitur, motion for judgment on the  pleadings, settlement agreements, and case management reports. 

   Miscellaneous Legal Writing Projects   

Kathleen has experience  preparing many different types of legal documents including, inter alia, application for attorney’s  fees, stipulation, subpoena duces tecum,  notice of deposition, status conference report, proposed orders, good faith certificates, Registrar of Contractor complaint, arbitration brief, notice of  non-party at fault, notice of deposition, certificate of complexity, notice of  errata, order to show cause, temporary restraining order, settlement conference  memorandum, application for appointment of receiver, declarations and affidavits.