510 Cherry Street
Scranton, PA 18505
Telephone Number (570) 909 3250, (347) 249 3083
Legal Researcher and Writer (Independent)
1987-Present , N.Y.S, NJ and Pa.
Specializing in researching and providing Case Law and Statutes, in support of appellate and pre-appellate case preparations and readiness with respect to pleadings, memorandum/briefs applications/motions, pre- trial discovery together with opposition interrogatories etc.
Provide’ instant and continuous support in the preparation court documents and inspect its readiness for filing and/or submission at schedule court engagements (hearing trial )
Independently and unsupervised prepares and draft’s, any application motions, affirmations, Note of Issues Subpoenas, Pretrial Discovery and any Court document on all levels of Jurisdiction .
Filing court papers, reviewing and inspecting documents of the court files/records respect to the assigned case (s), discovering and distinguishing strength and weakness, sharing findings with the client of assignment (employer) as well as the pursuit of continued follow up procedures.
Conducted pre -trial or interim investigation(s) gathering further facts and locating witnesses and or evidentiary proof to support the assigned case and or to shred or weakens the position and standing of that of the litigating/prosecuting opposition on client(s) behalf.
Making court appearances with respect to adjournments, preparing and filing short form Notices of Appearances for attorney or Notices . Fully grounded in Civil Procedure Laws and Rules (C.P.L.R.) and the Domestic Relations Law (D.R.L.) by virtue of the assisted practice in the preparations of Matrimonial, Contested/ Uncontested Divorce drafts (a heavy flow of “motion” practice support familiar with the procedure) Subrogation proceedings via Insurance Carrier’s Claims Department and/or Self Insurer Law Firms . Real Property Law- Prepared/ drafted Legal Instrument re: Real Property Closing (including but not limited to title background search ).
Heavy Litigation experience. Started cases at infancy of file without oversight supervision, managing credibly case files the completion (Trial or Settlement) in relation to divers areas of ligation, skillfully handled by me.
Post- conviction case matters, from State up to the Federal Level, (Heavy Motion and Brief Preparation(s). Pre and or Post Deportation. Heavy Immigration Appeals, and Adjustment of Status applications and post application.
Knowledge of Immigration -Application Forms preparation,.
Civil Rico Cases. On Federal Level.
TRIAL PREPARATION INVESTIGATIVE
N.Y.S. and the Tri State Areas
AMERICAN EXPERIENCE 1985-Present
Investigate cases by assignment of Plaintiff/Defense Law Firms, various areas of litigation, finding and locating people, places and/ or facts, for the strengthening of the client’s case. Obtaining photographs of accident/incident scenes, determining actual Injuries, damages on any tort related situation in respective cases. Locating and Interviewing witnesses (independent or of the Client’s) , collecting detailed signed statements, preparing Judicial Subpoenas and obtaining execution on the ones that are to be “so ordered”, serving same. Locating treatment doctors and /or Medical Institutions that have treated the injuries and obtaining all Narratives and Reports, MRI’s. Continuous follow up on most treatment visits ensuring the client’s full knowledge of their client’s progress is without lacking . Ensuring that all medical reports obtained are certified by the treating physician or medical institution that treated my client’s clients. Escorting witnesses to court, “EBTs”/Depositions, Doctor Offices if necessary and other exigencies of civil litigation..
1989 (external studies)
MSc. Criminal Justice Management
1997 (external studies)
JD Program, 2006 ( External Studies / not completed)
NOTARY PUBLIC- NYS & NJ
REFERENCE - Upon Per Your Requests