I thought the first three weeks were busy . . . until I experienced week four. Interestingly enough, we did not have any seminars or workshops this week, but the workload seemed to be much more intense! Towards the beginning of the week, I worked on a Response to a Motion for Order to Show Cause. I also researched an interesting topic on what constitutes appropriate collateral sources to set-off damages, which I would later write a memo on and submit to the firm’s managing partner, Frank Sheppard.

The biggest assignment I tackled this week was a Motion for Judgment on the Pleadings. I worked very closely with partner, Charlie Mitchell, on this Motion and learned so much throughout the process. We spent the first half of the week bouncing ideas off of each other and talking strategy of how we wanted to approach the Motion to respond to the rather poorly-written Complaint. Once we solidified a game plan, Charlie had me write up a detailed outline of all the arguments that we would make in our Motion. He gave helpful feedback on my outline and then I was on my own to draft the Motion! I was actually excited to start writing since we spent a good amount of time going over our arguments. I really felt like I understood the arguments inside and out, which made the drafting process much easier. However, since the Complaint was very unorganized, I found myself having to organize the Complaint’s arguments first for the opposing party and then organize my own arguments for our Motion. Once I finally finished drafting, I realized I would be thankful in the future for an organized Complaint from opposing counsel.

On Wednesday I attended a client presentation. I learned a ton about first-party and third-party insurance claims, as well as ethical requirements insurance companies must follow. As week five approaches, I can’t believe I’m almost halfway through the summer!