Sample Briefs

In May 2010, we filed an amicus curiae brief on behalf of the Western Manufactured Housing Communities Association in an important takings case reheard en banc by the Ninth Circuit. The case concerned the constitutionality of a mobilehome rent control ordinance adopted by the City of Goleta. Click here for a copy of the brief.
In our most recent victory, we represented an attorney who filed an anti-SLAPP motion to strike a malicious prosecution action, and the trial court not only denied the motion but deemed it frivolous and assessed attorneys’ fees against him. After careful review, we prosecuted an appeal and the California Court of Appeal, First Appellate District (San Francisco), not only reversed but remanded with directions to grant the anti-SLAPP motion in its entirety. Click here for our principal brief and the resulting opinion.
In 2008, representing a group of investors in a limited partnership venture in the California Court of Appeal, First Appellate District, we obtained affirmance of $1.4 million judgment over the defendants’ challenge to the proper measure of fraud damages and prejudgment interest. Click here for our principal brief and the resulting opinion.
Also in 2008, representing a New York entertainment company and its principal in a complex bankruptcy malpractice case in the Ninth Circuit Court of Appeals, we obtained a reversal of one significant portion of the judgment. Click here for our principal brief and the resulting decision.
In 2005, after owners of a mobilehome park had suffered an adverse decision in the California Court of Appeal, Fourth Appellate District, Division One (San Diego), on a complex state preemption issue, our firm was retained to seek relief in the California Supreme Court. We obtained a grant of review and a unanimous reversal. Click here for our principal brief and the resulting opinion.
In 2001, representing Manufactured Home Communities, Inc., (currently known as Equity Lifestyle Properties, Inc.), the nation’s largest owner of upscale mobilehome parks, in the California Court of Appeal, Sixth Appellate District (San Jose), we obtained a published opinion reversing a $6 million punitive damages verdict. The main ground was a statutory construction argument advanced for the first time on appeal. Click here for our principal brief and the resulting opinion.
In 1997, representing Uniroyal (Michelin) Tire Corporation in the California Court of Appeal, Fourth Appellate District, Division One (San Diego), we obtained reversal of an $8.4 million compenatory damages verdict. The main ground was the trial court’s refusal to instruct the jury on plaintiffs’ comparative negligence in riding at freeway speeds in the back of camper truck not equipped with seatbelts. Click here for our principal brief and the resulting opinion.
In 1995, representing a major North Bay developer in the California Court of Appeal, First Appellate District, we obtained a published and oft-cited opinion reversing a $1.4 million verdict in a partnership dispute. The trial court had improperly aborted the testimony of a key witness, and excluded any further testimony, on the basis of the court’s own assessment of his veracity. Click here for our principal brief and the resulting opinion.

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