PROMINENT ASSIGNMENTS Served as lead counsel in multiple bench trials with successful results. Drafted Motion for Summary Judgment for trucking client in a wrongful death case filed in the United States District Court for the Eastern District of Tennessee that resulted in complete dismissal of the case against client. Drafted Motion to Dismiss and successfully argued that clients were entitled to the dismissal of the plaintiff's claims pursuant to the doctrine of quasi-judicial immunity and the Tennessee Governmental Tort Liability Act. Drafted Motion to Dismiss and successfully argued that clients were entitled to the dismissal of the plaintiff's claims for negligence and false light invasion of privacy. Drafted Motion in Limine and successfully argued that the doctrine of collateral estoppel applied to the plaintiff's claim for defamation in light of decisions reached by the ALJ and the Chancery Court for Davidson County, Tennessee. Drafted Appellate Briefs for appeals currently pending in the United States District Court for the Sixth Circuit and in the Court of Appeals of Tennessee at Nashville. Drafted Motion for Summary Judgment for case pending in the United States District Court for the Middle District of Tennessee at Cookeville. Drafted Appellate Brief for a case appealed to the Court of Appeals of Colorado in which the Court of Appeals affirmed the district court's grant of summary judgment in favor of client. Drafted Response to a Rule to Show Cause in a matter of first impression in which the Supreme Court of Colorado adopted the position argued in Response brief.
