jelena yeargain

* Privately Held * Myself Only * Law Practice industry

* Advise corporate clients on whether to deny or affirm financial institution and surety bond claims. * Manage discovery process under both the Texas Rules of Civil Procedure and the Federal Rules of Civil Procedure, including prepare discovery requests/responses and privilege logs, and review/analyze produced documents and discovery responses. * Prepare subpoenas for documents and witnesses. * Prepare deposition outlines and conduct depositions in complex surety cases. * Conduct legal research and prepare legal memoranda, pleadings, and motions in both federal and state court. * Conducted mediation.

* Managed litigation caseload of over 60 active cases. * Drafted pleadings in federal court, including Notices of Removal, successful Motions to Dismiss, successful Motions for Summary Judgment, and Answers with Affirmative Defenses. * Prepared litigation status reports and budgets for client review on a quarterly basis.