Trial Briefing
For the past thirteen years, the majority of my work has been supporting trial lawyers. I have prepared and won motions to remand; responded to motions for summary judgment; prepared trial briefs in a variety of cases; responded to Daubert/Robinson motions; and prepared the briefs necessary to make sure my team gets their evidence before the jury. I have assisted in jury selection, including preserving Batson complaints and supporting challenges for cause with case law.
Consider hiring me to help prepare the
legal briefing to get your case to the jury. I can
respond quickly and efficiently to motions designed
to derail your case, and affirmatively prepare the
motions and briefing you need. All without distracting
the trial attorney from the work that only the trial
attorney can do.
For the past thirteen years, my practice
has primarily been focused in the area of complex plaintiff's
personal injury and health care fraud. I am admitted
to practice in Texas state courts and in the following
federal courts: the Fifth and Tenth Circuit courts
of appeal and all of the federal districts in Texas.
I have appeared pro hac vice in cases in Arizona, Kansas,
Missouri, Illinois, and North Carolina. I have participated
in two federal MDLs, one in Ohio and one in the District
of Columbia.
Below
are case descriptions and links to representative samples
of trial briefs prepared by Ms. Shackelford:
Rowmec v. Gyro-Trac, USA,
is a breach of contract relating
to a heavy equipment dealership. I was hired shortly before
trial by lead counsel Chris Bandas to assist with the
pretrial order and pretrial motions. The
case was tried in Houston in the Summer of 2007. Rowmec
obtained a judgment in the amount of $3.6 million which
was appealed to the Fifth Circuit by the defendants. Before
trial, Gyro-Trac filed a Daubert motion to exclude
Rowmec's economic expert. Rowmec's response and the
order denying the motion are linked.
A number of post-trial motions were filed by Gyro-Trac
including a motion for new trial. Rowmec's response and
the order denying the motion are linked from the court
documents.
Document Link >
Fierro v. General Motors Corp.,
is a wrongful death and serious injury case arising out
of the rollover of a Chevrolet Suburban. General Motors
removed the case to Federal Court. The Fierro's successfully
obtained remand to state court. Allene Evans of Austin,
Texas and Donald H. Slavik from Milwaukee were trial counsel.
Copies of the court documents relating to plaintiff's motion
to remand and the order remanding the case are linked.
Document Link >
During trial General Motors claimed that the death of one Fierro family member was caused by his preexisting medical conditions, rather than the head injury he sustained in the collision. We succeeded in preserving that issue for the jury. The Memorandum of Law on New and Independent Cause is linked.
Document Link >
Benavides v. John Michael Faust,
is a wrongful death case arising out of the death of a
contractor at Sherwin Alumina during a tank cleaning
operation. Sherwin Alumina filed a motion for summary judgment
seeking dismissal of plaintiff's claims pursuant to Chapter
95 of the CPRC (Civil Practice & Remedies Code).
Perry & Haas,
L.L.P. represented the Benavides family. The trial court
denied the motion and the case subsequently settled for
a confidential amount. Plaintiff's Response to Sherwin's
motion for summary judgement and the order denying the
motion are linked.
Document Link >
Howell v. Ford Motor Co.,
is a North Carolina wrongful death case brought by Perry & Haas,
L.L.P. against Ford Motor Company arising out of the deaths
of three young women after the Town Car Limousine they
were riding in caught fire after a rear-end collision.
The case was settled for a confidential amount on the eve
of trial. During preparation for trial, Ms. Shackelford
responded to and prepared a number of pretrial motions,
including Ford's motion for partial summary judgment relating
to plaintiffs' claim of inadequate warnings. The trial
court did not rule on the numerous pretrial motions due
to the settlement in the case.
Metzler v. Ford Motor Co., is a wrongful death claim arising out of the death of Officer Patrick Metzler, a City of Dallas police officer after his Crown Victoria Police Interceptor was struck in the rear and burst into flames. Perry & Haas, L.L.P. represented the surviving parents. During the course of that litigation and other related litigation, the depositions of several high-ranking Ford executives were scheduled. Ford tried to prevent the depositions from going forward. Plaintiff's Response to Ford Motor Company's Motion to Quash is linked. The trial court denied Ford's motion.
Document Link >
Boudloche v. Dairyland County
Mutual, is a Stower's case filed in
the Bankruptcy Court in the
Southern District of Texas. Perry & Haas, L.L.P. represented
the bankruptcy trustee. Ms. Shackelford second-chaired
the suit against Dairyland that resulted in an $8.5
million dollar judgment after a four-day bench trial.
The case was settled for a lesser confidential sum
while on appeal.
Corona v. Ford Motor Co.,
a wrongful death case filed in Edinburgh, Texas, arising
out of a collision that caused a rollover of a 1992
Ford explorer. Plaintiffs claimed that Juan Corona
was wearing his seatbelt and the failure of the seatbelt
latch to remain closed, and the improper opening of
the Explorer’s left
front door during the collision caused Mr. Corona’s
fatal injuries. Juan Corona was survived by his
widow and three young children. Ms. Shackelford
assisted with the trial briefing. The case was
settled after three weeks of trial for a confidential
amount. It is very common for the defendant in
these cases to attempt to exclude plaintiffs’ expert
witnesses. A link is provided to the brief opposing
exclusion of plaintiff’s biomechanics expert. Document
Link >
Nueces County v. Ford Motor
Co., Plaintiff,
Nueces County, sued Ford over fuel system defects in
its crown Victoria Police Interceptors. Ford Motor
Company removed the case to federal court. Plaintiff’s
First Amended Motion to Remand is attached. After
two years, and consolidation with other similar cases
into an MDL, the case was remanded, In re Ford Motor
Co. Crown Victoria Police Interceptor Products liability
Litig., No. 1:02 CV 15000, MDL Docket No. 1488, 2004
WL 1170145 (N.D. Ohio May 19, 2004). Document
Link >
St.
Clair County v. Ford Motor Co., filed
in St. Clair County, Illinois was a class action
on behalf of Illinois law enforcement seeking damages
for defects in their Crown Victoria Police Interceptor
fuel systems. Perry & Haas, L.L.P. represented
St. Clair County. Ms. Shackelford handled nearly
all of the extensive trail briefing.
The Shackelford Law Firm, Perry & Haas, and the Allene Evans Law Firm, three independent law firms practicing cooperatively.
The Shackelford Law Firm does not offer any guarantee of case results. Past success in litigation does not guarantee success in any new or future lawsuit. This website describes some of the cases that Shackelford Law Firm has worked on in the past. The description of those cases is summary in nature. You should be aware that the results obtained in each of the cases we have worked on was dependent on the particular facts of each case. The results of other cases will differ based on the different facts involved.
