PRE-TRIAL: Developing a strategy.
Houston Dunn offers a broad range of services during the pre-suit and pre-trial phases of a case, with a focus on legal research, strategy formulation, and drafting. Pre-suit, we can augment the depth of analysis before a case is filed by assisting in the development of pre-suit strategies for claims, defenses, parties, forum selection, and settlement. Pre-trial, we assist trial counsel in preparing a case for trial by handling law-intensive motions and legal briefing, including:
  • Motions addressing jurisdiction, venue, and choice of law
  • Removal and remand
  • Motions for summary judgment
  • Discovery and evidentiary disputes
  • Expert issues

TRIAL: Protecting the record.
Houston Dunn provides guidance and support at critical stages in the trial on issues that can make a difference on appeal. We assist trial counsel with briefing and preservation of error during all phases of trial, including:
  • Jury selection, evidence presentation, closing argument, and receipt of the verdict
  • Trial briefs addressing legal issues raised during trial
  • Motions for directed verdict
  • Jury charge preparation and argument
  • Motions to disregard jury findings, requests for findings of fact and conclusions of law, motions for new trial, and related post-judgment motions

APPEAL: Sharpening the focus.
Houston Dunn’s lawyers have extensive experience pursuing and defending traditional appeals in intermediate state and federal courts of appeals, interlocutory appeals to state and federal courts of appeals, and discretionary appeals to courts of last resort. We also prepare Amicus Curiae briefs to appellate courts. Our representation covers the entire appellate process:
  • Analysis of legal issues for appeal
  • Evaluation of settlement potential
  • Preparation of appellate briefs
  • Presentation of oral argument

ORIGINAL PROCEEDINGS: Navigating the unexpected.
In addition to handling appeals, Houston Dunn can initiate and pursue original proceedings in appellate courts to seek immediate—and sometimes emergency—appellate review of interlocutory trial court orders across a broad spectrum of substantive legal areas. As with conventional appeals, our services include preparation of appellate briefs, oral argument, and motions for emergency relief.