David H.

I have a background in law, worked for 17 years as a legal researcher and writer for two law firms in California, 1988 to 2005. My areas of expertise include personal injury plaintiff and defense including medical malpractice plaintiff, insurance bad faith litigation plaintiff and defense, contract law especially contracts of insurance, insurance coverage opinion letters, administrative law defense, appellate work. I am essentially an unlicensed lawyer. I have researched and written about hundreds, if not thousands, of subjects. By my own estimate I have read approximately 7,000 appellate court opinions during the course of my litigation work, primarily California law but also federal and other state law. I have written certainly more than 1,100 memoranda for internal use in a law office or for filing at court, including about 600 motions. I was heavily involved in all aspects of the cases, from an initial case analysis sent to an insurance company (at the defense firm, the first one I worked for), to pleadings including complaints, discovery, law & motion work, trial preparation and trial including trial and mediation/arbitration briefs. The law & motion work included numerous motions for summary judgment/adjudication, motions to compel, motions in limine, demurrers, motions to dismiss, both moving and opposition as to all. I have done appellate work in California, Pennsylvania, and Southern District New York federal court. By way of brief explanation of how I claim that I functioned essentially as a lawyer: around 1990 the insurers in California all but froze hourly rates paid to their defense firms; this freeze lasted a number of years. The firm I was with had three partners and about four associates. In an effort to trim expenses and live within the budget allowed by the frozen rates, all the associates were laid off and I became "the associate", doing almost all the research and writing (as opposed to matters such as taking depositions that by law must be done by licensed lawyers) that would usually be done by lawyers. I had been with the firm for two years when this situation developed and had done a little such work for one of the partners and had done it well — right skills, right place, right time. Through Upwork, I have worked with, among others, a pro se client defending foreclosures, bankruptcy proceedings, and appeals in New York and New Jersey, in both federal and state courts; a pro se client in California prosecuting a C.C.P. § 338 (trespass and taking) cause of action; a client in Maryland in cases that will be filed in small claims court; a lawyer assisting him with plaintiff insurance bad faith litigation; and more. I have written on labor law, researched the law of marine sanctuaries, worked with a Los Angeles lawyer to write demand letters and help her settle cases, helped a pro se defendant represent himself in federal court in a RICO case, worked with a Utah lawyer in general civil litigation, prepared appeals for two pro se defendants in repossession cases in Pennsylvania and New York, and more. Apart from my legal work, I have a varied background. I worked for seven years as a welder in California shipyards.  I rebuilt a Volkswagen engine using the popular Idiot's Guide to Keeping Your Volkswagen Alive. I have broad experience of life, am an adventurer and an intellectual, have extremely well-developed skills in logic, researching, and writing, can keep to tight deadlines, and have a keen sense of people.  I have kept an extensive journal during my travels (to 26 countries). I have a wide scope of knowledge and voracious reading habits; areas that I have significant familiarity with include law, history, geography, sciences, mathematics, languages, and the environment.  I am self-directed, fully capable of handling significant projects independently.