Contrary to what you see on TV and in the movies, most legal work—and especially the legal work that matters most—occurs outside the courtroom. Legal and evidentiary issues are written and briefed and submitted to the court well in advance of the trials and hearings. This is true even in criminal cases where issues like suppression of evidence and the constitutionality of statutes are presented in advance of trial. It's especially true in federal criminal sentencings where the sentencing hearing itself merely formalizes all the work already written, prepared, and presented to the court.
The bottom line for lawyering is this: if you can't research and write well, you just aren't as good a lawyer as you can be—or your client needs you to be. We're—justifiably, we think—proud of the caliber of our legal work and writing. Below are some samples for your information. In some cases, they've been redacted to protect sensitive information.
Here's the appellate brief that convinced the DA to agree to an expunction referenced on the Successes page.
In a recent case, opposing counsel sought to have our client held in contempt. We filed this response to the show cause order. After a hearing consistently mostly of opposing counsel's arguing with the judge, the request to hold our client in contempt was summarily denied. But opposing counsel wasn't one to be deterred. He refiled again seeking to hold our client in contempt. After we filed another response, opposing counsel cancelled the hearing.
This is a motion to dismiss for a constitutional speedy trial violation. In light of this motion, the prosecutor conceded the problem and dismissed the charge outright without hearing.
Here's a motion for a sentencing variance arguing—successfully—why the client in a federal gun trafficking case deserved a sentence well below the sentencing guidelines range. (Much of it is redacted for privacy concerns.)
In a federal methamphetamine conspiracy case, we negotiated a 180 month maximum sentence for our client. The Presentence Report calculated the client's Sentencing Guidelines range as 235–293 months and recommended that the district court reject the 180–month sentence cap. We filed a Sentencing Memorandum explaining why the cap was justified and why the Sentencing Guidelines calculation overstated the client's culpability. The district court accepted the cap and sentenced the client to 180 months notwithstanding the PSR's Sentencing Guidelines calculation and recommendation.
Here's the writ application and brief in support with exhibits that resulted in the vacation of the client's sentence in a robbery case and his re-sentencing to time served referenced on the Successes page.