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Patricia L Brown & Associates

Mutual Release of Business Interest

Like all relationships sometimes business relationships break apart. In this case my client had been in business with two friends. They had operated two distinct businesses but now wanted to go their separate ways. They had…more

| Business Organizations, Commercial Law & Contracts

Release of Records Authorization Form

Many financial institutions require that a release of record be signed by a client before releasing any records to an attorney. The contract between the attorney and client is often not sufficient for the financial institution…more

| Civil Procedure, Finance & Banking

Driving; Negligence Pe Se Research Memorandum

Negligence per se is the legal theory that a person may be negligent due to the violation of a public duty under a law that defines the failure of care required to constitute negligence. In other words if a law states that a…more

| Personal Injury

Sample Personal Injury Deposition Questions

Depositions are an opportunity for the attorney to ask questions of a potential witness, outside of the courtroom. The witness’s responses sworn to by the witness and are taken down by a court reporter or by video. The…more

| Civil Procedure, Personal Injury

Guardian Ad Litem Report

When injuries to children are the subject of settlement, Courts often appoint an attorney to represent the children for the purpose of determining whether the settlement offered is what is best for the child. The idea is that…more

| Civil Procedure, Civil Remedies, Personal Injury

Affidavit of Heirship Template

Several forms of probate require that disinterested witnesses swear to certain facts regarding the deceased. Specifically, the probate code requires that the heirs of the estate be identified by sworn testimony or affidavit…more

| Civil Procedure, Wills, Trusts, & Estate Planning

Waiver of Service

The Texas Rules of Civil Procedure require that parties to law suits be provided with notice of the pending suit. This is generally accomplished by having the party personally served, although there are other methods of service…more

| Civil Procedure
Duncan v. Farmers Insurance Exchange

Plaintiff's Response To Defendant's Motion To Sever and Abate and Motion For...

One of the most common tactics by an insurance carrier that is being sued under its uninsured/underinsured motorist (UM/UIM) coverage, is to move the court to sever the case into more than one trial, or to “abate” (i.e.,…more

| Civil Procedure, Civil Remedies, Commercial Law & Contracts, Insurance
Duncan v. Farmers Insurance Exchange

Plaintiff's Response To Defendant's Motion For Separate Trial On Exemplary...

Another common tactic of an insurance carrier is to try and bifurcate (i.e., separate) the trials on the contract violations and the trial on exemplary damages. In this case, however, our firm had already carefully pled in the…more

| Civil Procedure, Civil Remedies, Commercial Law & Contracts, Insurance

Trademarks and The Lanham Act: Research Memorandum

This is a memo containing a review of my research regarding Trademarks and the Lanham act. In this case my client’s website had certain words that drew in more traffic that the opposing party did not think were proper, including…more

| Intellectual Property

Requirements to File Suit on Discrimination in the Workplace - Research...

This memo was prepared to update a senior partner on the requirements of filing a suit by a teacher for discrimination in the workplace. In this case the client was passed over for promotion in favor of a male teacher who less…more

| Civil Procedure, Civil Remedies, Civil Rights, Education, Labor &...

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