Week 3 2018

Drafting an Entire Motion to Dismiss to Depos

Drafting an Entire Motion to Dismiss to Depos

Week 3 came and went faster than either of the previous two weeks, mostly because of how many different assignments I got a chance to work on! From sitting in and taking notes on a phone deposition, to conducting a practice deposition as part of a summer associate workshop, to drafting an entire motion to dismiss on six different counts, I could not have learned more or worked any harder.

At the start of Week 3, I was first tasked with writing a motion to compel and a summary of plaintiff’s discovery in a couple of insurance cases. I had never written any motions from scratch before, so that was a very valuable experience. Then, after conducting some research for a couple of aviation cases on jurisdiction issues, I spent almost all of Wednesday sitting in on a phone deposition and taking notes. The deposition was not being given by a Rumberger attorney, but it was of an expert, so I found it fascinating.

On Thursday morning, I received by far the biggest assignment yet: drafting an entire Motion to Dismiss addressing five separate counts. I not only had to spend most of Thursday and Friday working on this project, but also conducted some research over the weekend so I could come into the office on Monday ready to write most of the analysis. The issues were particularly challenging because there were very little cases on point out there, especially in controlling courts, so I had to find favorable cases with other fact patterns that I could use to support the ruling that we wanted from the Court. I still have not finished the assignment yet, but anticipate being done with it soon and so far am very proud with the product that I have produced and all of the research that I have conducted.

Other than working on that motion to dismiss, I also participated in the taking depositions workshop with Darryl Gavin from the Orlando office on Friday morning. That exercise was extremely valuable for me as I had never given a practice deposition before, and Darryl gave me great feedback on what questions I should and should not have asked. He told me that I did a great job and to just make a couple minor tweaks, but that I seemed confident and asked pertinent questions.