Enclosed are several writing samples for your review.  You will notice that the writing style is concise and never wordy, and our case citations include page cites and, where necessary, concise parentheticals to assist the court in its review of the filing.   

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Writing Sample #1:

Appellant’s Initial Brief – Seeking reversal of summary judgment – trial court erred by failing to require appellee to conclusively disprove appellant’s affirmative defenses – trial court erred by failing to consider affidavit evidence submitted by appellant during interval between court’s entry of summary judgment and court’s sua sponte continuation of summary judgment hearing   

Writing Sample #2:

Memorandum In Opposition to Defendant’s Motion to Dismiss for Lack of Personal Jurisdiction/Subject Matter Jurisdiction – Defendant’s affidavit evidence insufficient to shift evidentiary burden to plaintiff to produce evidentiary materials in support of forum court’s personal jurisdiction – forum court retains subject matter jurisdiction to hear subject lawsuit even if identical lawsuit with same issues/parties is pending in another state.      

Writing Sample #3:

Motion for Summary Judgment – Defendant made timely withdrawal of offer to purchase real estate because (1) Plaintiffs never effectively accepted Defendant’s offer  due to their failure to execute real estate agreement, and (2) parties never had “meeting of the minds” regarding acreage to be purchased, acreage being an essential element of real estate purchase agreement.     

Writing Sample #4:

Memorandum in Opposition to Plaintiff’s Summary Judgment Motion – Plaintiff failed to submit sworn authentication evidence in support of its documentary evidence – Plaintiff failed to conclusively negate Defendant’s affirmative defenses – Defendant, as non-moving party, is under no obligation to offer evidence in support of its lost profits counterclaim.    

 Writing Sample #5:

Appellee’s Answer Brief – trial court did not abuse its discretion by using its broad discretionary authority to modify final judgment of dissolution of marriage to expand appellee’s visitation rights to include weekday overnights during school year  - trial court did not abuse its discretion by overruling appellant’s petition to relocate – trial court did not commit reversible error by discussing visitation issues during in camera interview with parties’ minor children