Patty devotes a significant part of her practice to providing consultation and assistance to other lawyers by evaluating legal claims arising in the workplace. Whether the forum is mediation, arbitration, or litigation, Patty provides the needed backup and support to attorneys who are navigating civil rights agencies and other legal enforcement bodies, or who are engaged in traditional adversarial litigation in state and federal trial and appellate courts.

Investigation and Informal Discovery

Prior to litigation, Patty has been engaged to assist attorneys in evaluating claims and possible defenses by interviewing witnesses and preparing legal declarations. She has also gathered relevant information from available resources before formal discovery including developing, preparing, and reviewing public records requests and verifying social media presence. Patty has also benefitted attorneys by conducting database research on relevant corporate policy practices and litigation history.

Formal Discovery

Local, state, and federal rules of civil procedure are increasingly placing limits on discovery and inhibiting employment plaintiffs from gaining access to information that is often exclusively in the custody of the employer. Patty has drafted all forms of written discovery materials including narrowly tailored interrogatories, requests for production, and requests for admission. She has also reviewed draft responses and answers to written discovery from the opposing party and reviewed production documents. In addition, Patty has prepared deposition outlines for CR 30(b)(6) designated representatives and other fact and expert witnesses, as well as prepared chronologies of events, deposition summaries, and other litigation support.

Legal Research and Writing

Employment disputes involve a range of legal claims arising in statutes, common law, and even constitutional provisions. Because of her extensive experience in the developing area of employment law, Patty understands precedent as well as the policies and regulations that implement the many statutes governing the employment relationship.

Many small firms or solo practitioners turn to Patty for legal research on affirmative defenses and counterclaims identified in initial pleadings as well as legal research and analysis of unanticipated issues. These services range from identifying and providing relevant case law and citations to detailed preparation of research memoranda to inform discussions with clients and opposing counsel.

Lawyers often find themselves with competing deadlines. Unlike Patty, many do not enjoy research and writing. Patty has drafted demand letters and mediation briefs that have assisted counsel in obtaining settlements before trial. She has also written pleadings including complaints, answers, and pre-trial motions. These pleadings have included motions for injunctive relief, motions to compel discovery, and most frequently memoranda supporting and opposing summary judgment

Trial Support

As trial approaches, Patty has stepped in to create pre-trial statements, proposed orders, trial briefs, motions in limine, and jury instructions. She has on occasion drafted direct- or cross- examination questions and engaged in witness preparation. Similarly, she has prepared pleadings on post-trial matters, drafting findings of fact and conclusions of law and attorney fee petitions.

Appellate Briefing

Appellate briefing is another area where Patty has provided services to other employment lawyers. Patty has reviewed trial transcripts and other portions of the record, and designated clerk’s papers and excerpts of record. She has assisted others in preparing briefs for submission, including citation checking, creation of tables, and proofreading and other technical editing. Patty has also been engaged to develop appellate briefs for other lawyers.

Association and Appearance on Cases

On select matters, Patty will consider formal association and/or enter an appearance on litigation initiated by other attorneys. On such occasions, she has helped create themes for opening statements and closing arguments, assisted in jury selection, argued motions in limine, examined witnesses, prepared bench briefs, and argued exceptions to jury instructions.