PRACTICE AREA · LITIGATION

Motions & Briefs

File the brief you’d write if you had the time.

I write motions, oppositions, replies, emergency briefing, and appeals, so your trial team stays on the case and the filing that decides it gets the hours it needs. You review it, sign it, and file it under your name.

500+

500+

Contested cases handled

$1,190

$1,190

Flat fees from

1 business day

To a written scope and fee

Zero

Zero

Missed filing deadlines

WHAT CHANGES

What it looks like when nobody has time to write it.

01

01

A motion to dismiss comes in the week you’re preparing for trial. Your associate stays on trial prep. I write the motion.

02

02

The other side moves for summary judgment on a 900-page record. I read the whole record.

03

03

A client wants to appeal. You keep the appeal instead of sending it to another firm.

WHAT I DRAFT

Filings I handle, and what each one costs.

Every filing has its own standard and its own way of going wrong.

Complex pleadings

Custom complaints for multi-party or high-stakes matters, plus answers with affirmative defenses, cross-claims, and third-party complaints. Researched and built from scratch.

$1,190–$3,400

ABOUT 7–20 HOURS

TROs and preliminary injunctions

Emergency briefing on the four factors under Winter, with irreparable harm tied to actual evidence. Orders to show cause included.

$255/hr priority

QUOTED ON SCOPE

Motions to dismiss

Rule 12(b)(6), 12(b)(1), 12(c), and state demurrers. I test the complaint element by element against Twombly and Iqbal and build around the allegation that fails.

$1,700–$3,400

ABOUT 10–20 HOURS

Discovery and evidentiary motions

Motions to compel, protective orders, motions to quash, and spoliation, with the meet-and-confer record and Rule 26(b)(1) proportionality analysis.

$1,700–$3,400

ABOUT 10–20 HOURS

Summary judgment

Rule 56 moving and opposition briefs with the statement of undisputed facts. Every fact pinpoint-cited and checked against the exhibit itself.

$3,400–$5,100 · Reply: $2,210–$3,400

ABOUT 13–30 HOURS

Oppositions and replies

I answer the other side’s strongest point first. Replies stay inside the page limit and don’t repeat the opening brief.

Opposition: $1,700–$3,400 · Reply: $1,360–$2,550

ABOUT 8–20 HOURS

Pretrial, trial, and post-trial

Motions in limine, trial briefs, jury instructions, findings of fact, reconsideration, new trial, and fee petitions.

Quoted on scope

—

Appellate briefs

Opening, answering, and reply briefs, rehearing petitions, and interlocutory appeals, with preservation and standard of review worked out issue by issue.

$3,400–$8,500 · Reply: $2,550–$5,100

ABOUT 15–50 HOURS

HOW I WORK

Three things I won’t shortcut.

01

The judge’s own rules

I check individual practices, page limits, and formatting before I write, not after.

02

The record before the argument

I build the argument from what the record actually shows, and check every factual claim against the transcript or exhibit.

03

The adverse case

If there’s authority against you, I find it and deal with it. You hear about it from me, not opposing counsel.

SENDING ME A BRIEF

What I need from you, and what you get back.

What you send me

  • The pleadings and relevant orders

  • The record, or the excerpts that matter

  • The court, the judge, and the deadline

  • Your house style and any templates

  • Your strategy, in as much or as little detail as you have

What you get back

  • A filing-ready draft formatted to the court’s local rules

  • Tables of contents and authorities where required

  • Every citation and factual claim verified

  • Revisions within the agreed scope

  • Delivery in time for your team to review and file

Standard turnaround is 6–10 business days. Emergency filings in 48 hours, subject to availability.

PRICING

Know the fee before I write a word.

I bill $170 an hour and quote every matter as a binding flat fee before I start. Not an estimate that grows. If the work runs long, that’s on me.

Standard

$170/hr

Priority (24–48 hours)

$255/hr

Deposit

50% upfront

Standard turnaround

6–10 business days

Complex pleadings

$1,190–$3,400

TROs and preliminary injunctions

$255/hr priority

Motions to dismiss

$1,700–$3,400

Discovery and evidentiary motions

$1,700–$3,400

Summary judgment

$3,400–$5,100 · Reply: $2,210–$3,400

Oppositions and replies

Opposition: $1,700–$3,400 · Reply: $1,360–$2,550

Pretrial, trial, and post-trial

Quoted on scope

Appellate briefs

$3,400–$8,500 · Reply: $2,550–$5,100

No charges for research platforms, calls, or emails. Revisions within scope included. Under ABA Formal Opinion 08-451, you may bill this work to your client, including a reasonable surcharge, if the total fee is reasonable.

WHY ME

What I’ve done, in numbers.

What I’ve done, in numbers.

Before founding Omega, I was a trial attorney in New York City’s federal immigration courts, where every case on my docket was contested. Here’s what that experience adds up to.

Before founding Omega, I was a trial attorney in New York City’s federal immigration courts, where every case on my docket was contested. Here’s what that experience adds up to.

500+

Contested cases handled.

An independent docket in New York City’s federal immigration courts, where the stakes in every case were whether someone could stay in the country.

500+

Contested cases handled.

An independent docket in New York City’s federal immigration courts, where the stakes in every case were whether someone could stay in the country.

Over 40

Merits hearings argued.

Live witness cross-examination and evidentiary disputes, so I write knowing what holds up in front of a judge.

Over 40

Merits hearings argued.

Live witness cross-examination and evidentiary disputes, so I write knowing what holds up in front of a judge.

Hundreds

Opposing briefs reviewed.

Finding credibility issues, statutory defects, and gaps in the record was part of my job. I read my own drafts the same way.

Hundreds

Opposing briefs reviewed.

Finding credibility issues, statutory defects, and gaps in the record was part of my job. I read my own drafts the same way.

5

Forms of relief litigated.

Asylum, withholding of removal, Convention Against Torture claims, cancellation of removal, and adjustment of status, each with its own standard and burden of proof.

5

Forms of relief litigated.

Asylum, withholding of removal, Convention Against Torture claims, cancellation of removal, and adjustment of status, each with its own standard and burden of proof.

All 50

States researched.

Before my trial work, I researched statutes in every state and turned them into legal documents used nationwide.

All 50

States researched.

Before my trial work, I researched statutes in every state and turned them into legal documents used nationwide.

$3,000

Bond, no government appeal.

For a Texas firm, in a Houston jurisdiction where the firm said bonds under $15,000 had become rare. Prior results do not guarantee a similar outcome.

$3,000

Bond, no government appeal.

For a Texas firm, in a Houston jurisdiction where the firm said bonds under $15,000 had become rare. Prior results do not guarantee a similar outcome.

I check every fact against the record and read every case I cite myself. That’s the part no one sees, and the part I never skip.

RESULTS

In their words.

RESULT

$3,000 bond

No government appeal. Houston.

“Bond granted, $3,000, government did not appeal. Those last two points are miracles these days. Nobody’s giving bonds under $15,000 in Houston, and the government is always appealing. Thanks for your part.”

Wendler Law Group, Texas.

Jack drafted the motion supporting the bond request.

“We highly recommend! They do quality work. Our experience was that they deliver on their word and will work out the right plan that works with your law firm.”

Kristy Wendler, Wendler Law Group, Texas.

Prior results do not guarantee a similar outcome.

QUESTIONS

Litigation questions.

Do you handle filings outside Arkansas?

Yes. I’m admitted in Arkansas and support firms nationwide. Your firm remains counsel of record, supervises the work, and signs and files under its own name. I draft to the forum’s local rules and the judge’s individual practices.

Can you take an emergency TRO or a short-notice response?

How do you handle summary judgment when the record cites are contested?

What do you need from us to start?

What if my motion isn’t listed here?

Have a motion due in the next 30 days?

Tell me the matter, the court, and the deadline. You’ll have a written scope and a binding flat fee within one business day.