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Commerce Bank Building
8700 Monrovia, Suite 208
Lenexa, Kansas 66215
Phone: 913-492-6200
Fax: 913-227-0149
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April 12th, 2011
I recently updated my website and I’ve added a blog. I will use my blog to periodically publish updates, articles of interest and commentaries. Please check back regularly for new information.
I hope you find the blog information interesting and useful. Thanks for visiting!
Tags: Law Office of Rodney K. Murrow, Rod Murrow
Posted in Firm News | Comments Off
January 3rd, 2012
Injunctions may be used to enforce a variety of rights, including rights under a noncompete, nondisclosure, nonsolicitation or similar type of agreement, particularly those related to unfair trade or business practices or involving trade secrets. By far, the most common use of an injunction in those situation is for a former employer to attempt block subsequent employment by one of its employees or former employees at an employer that it believes violates such an agreement. However, many employees don’t realize that it is also possible for them to seek injunctions against their current or former employers to stop them from interfering with employment by a new employer in the right circumstances. Injunction cases are very heavily fact-dependent, and injunction law varies from state to state. Those variations can be significant. The purpose of this post is just to explain only in broad terms what an injunction is and the procedures that are used in obtaining one.
An injunction is essentially designed to prevent a harm from occurring which would be difficult or impossible to remedy through payment of damages or through some other legal remedy. Injunctive relief is to prevent future wrongdoing and not to remedy past wrongs. Injunctions are considered “equitable” remedies rather than legal remedies, and come with different standards. The litigation of restraining orders and injunctions can be a time pressured process involving many of the same considerations as a trial on the merits. An injunction may either compel or prohibit a party’s future action.
There are three primary phases in the injunction proceedings, though in some circumstances different phases may be combined or omitted:
1. Temporary restraining order;
2. Preliminary or temporary injunction; and,
3. Permanent injunction.
In some states, a temporary restraining order may be issued without notice to the other side and without a hearing, while other states require a hearing before issuing a temporary restraining order. The temporary restraining order and temporary or preliminary injunctions are temporary orders, while the permanent injunction is a permanent order going forward.
Also, in some cases it is necessary to post a bond before the temporary restraining order will be issued. In some circumstance the requirement to post a bond may be waived. The purpose of the bond is to pay damages in the event that the restraining order or injunction is wrongfully issued.
The party moving for a restraining order must show that they are entitled to the relief requested, that they would be caused “irreparable” harm, and that there is no adequate remedy at law to address the injury . An applicant for a temporary or permanent injunction must generally establish a that there is a substantial likelihood of prevailing on the merits. These requirements can require an extensive analysis that is beyond the scope of this limited post, but it would be a large mistake to simply assume that a party does, or does not, meet these requirements until that analysis is done.
The process for obtaining a restraining order or injunction is started by filing the appropriate pleading in the right court. A temporary restraining order may be issued by the court immediately in those instance where a hearing is not required. Otherwise, the court will set a hearing very quickly. Each hearing held (whether it’s for a temporary restraining order, temporary injunction or permanent injunction) is essentially a mini-trial with evidence presented in the form witness and documents. Discovery is conducted as with any other type of litigation, though the time frames for completing this discovery can be greatly accelerated in some circumstances.
Because of how fact-specific these cases are and because of the variations in the law between different jurisdictions, the ability to obtain a restraining order or injunction can only be determined by an attorney with knowledge and experience in this area of the law. There is considerable misinformation among the general public about temporary restraining orders and injunctions, and it should never be assumed that a party can, or cannot, obtain an injunction (or defend against one) until this review has been done.
Posted in Contracts & Agreements, Non-Compete Agreements | Comments Off
August 7th, 2011
There are an increasing number of companies that are using independent contractors as opposed to W-2 employees. While many positions including commission sales have relied on independent contractors for years, there is a growing trend in having a company’s labor needs filled by independent contractors rather than employees. Many times the relationship is defined by a written agreement that defines the relationship as one of an independent contractor. There are substantial advantages to an independent contractor relationship in terms of reduced cost and potential limits on liability. However, many times an independent contractor agreement is not dispositive if the relationship is functionally treated as an employee-employer relationship.
Under Kansas employment law, an employment relationship is differentiated from one of an independent contractor relationship by the amount of control exerted by the company over the manner in which the workers carries out their job functions. In an independent contractor relationship, the company controls only the goals or results of the individual’s work but not the means of accomplishing those results. Kansas law uses a number of factors to evaluate whether there is enough control exercised over the means of carrying out one’s job functions to constitute an employment relationship including:
- Whether the work is supervised at the job site
- Does the company supply the work equipment and job location
- The payment method hourly employee vs. commission or piece rate
- The actual control exerted by the company over the means of carrying out job duties
- The degree to which the work constitutes a separate occupation or business
- Skill level required for the work
- If the service is continuous or isolated
- Whether the services benefit the employer as an individual or a business
- The degree to which the service provider can make judgements that effect profit or loss to the service provider
Generally, the point is that an employment relationship exists if the services provided are an integral part of the ordinary business of the company, and the service provider is not offering an independent business or professional service to the company. The ultimate classification is controlled by the actual conduct of the parties irrespective of any classification in a contract between the company and the service provider.
A growing number of companies are taking advantage of the economic benefits of classifying service providers as independent contractors. There are substantial advantages for companies including shifting tax burden to the service provider as well as potentially avoiding the expense associated with unemployment or worker’s compensation benefits.
By the same token, the cost to a person providing services of being characterized as an independent contractor is extremely high. The person must pay both income and self-employment taxes. This effectively means that the service provider is covering the portion of FICA that would be covered by an employer in a traditional employment relationship. The employee may also bear the risk of job loss or a job related injury.
Whether you are a service provider that is being incorrectly classified as an independent contractor or a company that is alleged to have misclassified your workers, Attorney Rodney K Murrow has more than 20 years of experience advising and representing both employers and businesses from Kansas and Missouri.
If you have a business or employment law issue, we are here to answer your questions. We have built a reputation for impeccable legal services with over 20 years of experience so contact us today at 913-492-6200.
Tags: Kansas business attorney, Kansas business law, Kansas business law firm, Kansas business lawyer
Posted in Independent Contrators | Comments Off
June 6th, 2011
Wage and hour laws can pose enormous problems for employers. These laws are widely misunderstood by many employers, and the liability for mistakes can be enormous. For employees, these laws offer protection from employers who seek to cut costs by failing to pay workers what is required by law.
However, on May 9, 2011, the US Department of Labor (DOL) just made it easier for employees to impose liability on their employers for mistakes or deliberate violations under the wage and hour laws. In a short press release, the DOL announced the launch of a free smartphone app, for use on an iPhone or iPod Touch, which allows employees to track hours worked for themselves, thus making it easier to prove hours worked and possibly overtime owed.
The app is available in Spanish and English and is available for download from the homepage of the Wage and Hour Division of the US Department of Labor. The app makes it simple and easy for workers to track their rate of pay, work start and stop times, and arrival and departure times. The DOL stated that it is exploring updates that would enable the app to also work on other smartphone platforms, such as the Android and BlackBerry.
The press release can be found at http://www.dol.gov/opa/media/press/whd/WHD20110686.htm
The app can be downloaded at http://www.dol.gov/whd/
Employers are strongly urged to have a thorough evaluation of all of their wage and hour policies, including employee classifications, to avoid common but very costly violations of wage and hour laws. For more information about such a review, please contact our office.
Posted in Small Business, Wage & Hour | Comments Off
April 5th, 2011
In the absence of a written employment contract, Kansas employees generally are designated as employees-at-will. The employment at will doctrine provides that the employment relationship can be terminated by either party for any reason or no reason at all. However, the harsh impact of the employment at will doctrine may be limited by an employment contract. Another limitation on the employment at will doctrine is that an employee may not be terminated based on illegal discrimination or for other public policy reasons. Approximate 250,000 employees are unjustly fired from their workplace annually. Victims of wrongful termination may have a right to pursue a wrongful termination lawsuit against their employer.
If your employer has fired you based on unlawful discrimination, violation of an employment contract or against public policy, our Kansas wrongful termination law firm represents employees who are wrongfully terminated in Federal or Kansas administrative hearings seeking relief. Once administrative remedies have been exhausted, we can also help you pursue a lawsuit in Kansas or Federal court depending on the circumstances of your claim.
We have provided a basic overview of some of the grounds that may constitute a basis for a wrongful discharge claim.
When an Employer Violates Kansas State Law of Federal Discrimination Laws
- Discrimination: A number Federal and Kansas statutes prohibit employment policies and decisions based on such factors as race, sex, age, religion, disability, national origin or citizenship. A termination that is based on any of these unlawful grounds may create a basis for pursuing a Kansas claim for wrongful termination or wrongful discharge.
- Whistleblower Protection: There are both Federal and Kansas statutes that provide protection against discharge to employees who report certain illegal, fraudulent or unsafe practice by their employer. Whistleblower protections protect employees against reprisals for reporting these types of illegal or unethical conduct by an employer.
While the law does not necessarily prohibit all terminations of an employee who falls into the above categories, the employer must have a legitimate basis for the termination. Wrongful termination or wrongful discharge cases often involve extensive investigation and analysis of a company’s documents, past records and patterns of hiring and firing as well as a careful analysis and evaluation of the employer’s stated basis for the termination.
When an Employer Violates a Public Policy
In Kansas, an employee may be able to pursue a wrongful discharge claim against a company if the employee’s discharge violates certain public policies. These public policies may be embodied in either Kansas or Federal law.
Below are a list of public policy violations that may constitute grounds for a Kansas wrongful termination claim:
- Termination of an employee for refusing to violate the law.
- Firing an employee for making a worker’s compensation claim.
- Terminating an employee who reports a violation of law by a company when it can or did harm the public.
- Firing an employee for exercising certain statutory or constitutional rights.
- Termination of an employee for responding to a subpoena or participating in a deposition for a civil lawsuit.
- Terminating an employee who insists on compliance with the Food, Drug and Cosmetic Act.
- Firing an employee for reporting or disclosing suspected criminal activities of a co-worker.
If you are the victim of wrongful discharge for any of the reasons above, you may have the right to file a claim for wrongful discharge against your employer. These cases are extremely complex and have many administrative, procedural and timing requirements. If you have a written employment contract, the requirements for initiating a wrongful termination claim may be impacted by provisions in your employment agreement. If your case is based on discrimination or the statutory protections of a Kansas or Federal law, such as a whistleblower statute, you will likely need to exhaust administrative remedies before pursuing a lawsuit. The time limits for initiating an administrative claim will typically be much shorter than the statute of limitations so it is important that you promptly seek the advice of an experienced Kansas wrongful termination attorney.
Our law firm has a firmly established reputation for providing innovative solutions to legal problems and persuasive advocacy on behalf of our clients. Our law firm has been representing clients in Kansas City and surrounding areas for more than 20 years. Mr. Murrow also lectures nationally at seminars on employment law matters, including sexual harassment, termination procedures, “non-competes” and employment contracts. If you believe that you have been wrongful terminated, call us today for your initial case evaluation at 913-492-6200.
Tags: Kansas Employment at Will, Kansas Wrongful Termination Attorney
Posted in Wrongful Termination | Comments Off
April 3rd, 2011
Should you represent yourself in a Kansas court in an auto accident case? While you are certainly permitted to represent yourself in a lawsuit for personal injuries suffered in a Kansas car accident, this does not mean that it is a good idea. It is appropriate to represent yourself in some limited situations like a small claims court case involving minimal property damages and no injuries. One of the main reasons why small claims courts exist is to provide a forum for litigating simple cases with relatively small sums at stake. However, this approach is not appropriate for Kansas auto accident claims involving damages in excess of $4,000.
Virtually any Kansas car accident that involves injuries will involve damages in excess of this nominal sum. If you are involved in a car accident and suffer any injury, you should seek immediate medical attention. It is critical to determine the extent and seriousness of your injuries, which will help you determine how to proceed. If you are diagnosed with any injury that will require treatment beyond minor scratches and bruises, you should seek the advice of an experienced Kansas car accident lawyer.
A layperson who tries to handle his or her own Kansas car accident will find navigating the court system complex as it is governed by formal rules of procedure and evidence that are complicated and confusing. For example, the hearsay rule, which generally bans the use of out of court documents or testimony that quotes a third party for purposes of proving what is asserted, has 23 exceptions under Kansas law. When it comes to the procedural and substantive complexities of navigating civil litigation in a personal injury lawsuit, the insurance company will have an experienced attorney representing its policyholder.
Most laypersons who attempt to handle their own case in a Kansas auto accident lawsuit will have a difficult time even having their case heard on its merits because the insurance company’s attorney will seek to have the case dismissed on a demurrer, motion for summary judgment or some other preliminary procedural motion. Many times the insurance company will be successful despite the merits of your Kansas auto accident claim. The insurance company knows that a layperson is likely to have his or her car accident lawsuit dismissed and will typically not offer any reasonable settlement because it does not fear the possibility of losing and having to pay a more significant judgment.
If you hire an experienced Kansas auto accident lawyer, you level the playing field. A Kansas personal injury attorney will be well versed in what factual evidence is necessary to prevail as well as the procedural and evidentiary requirements for successfully presenting that evidence. Your Kansas car crash attorney will know how to evaluate a proposed settlement offer from the insurance carrier based on prior judgments and settlements in similar cases. The insurance company will also be more inclined to offer a reasonable settlement offer because there is a genuine risk of a substantial jury verdict.
One reason that some Kansas auto accident victims are reluctant to hire an attorney is that they are concerned with the cost of hiring a personal injury attorney. This should never be a concern in a Kansas personal injury lawsuit because virtually all attorneys handle car accident cases on a contingent fee basis. “Contingent” means the payment of any fee is contingent on success. If you do not win, you do not pay any legal fees. If you do win, the Kansas auto accident law firm simply recovers a percentage of the judgment.
It is a good sign if an attorney agrees takes your case on a contingent fee basis because attorneys cannot afford to take bad cases on contingent fee agreements. If you have been involved in a Kansas auto collision resulting in significant property damage or any injuries that require medical care, you should promptly contact a Kansas City car accident lawyer. At the Law Office of Rodney K. Murrow, we have been representing those who suffer catastrophic injuries and wrongful death in car accidents in the greater Kansas City area for over 20 years. We offer a free initial case evaluation so call us today at 913-492-6200.
Tags: Kansas City car accident lawyer, Should I Represent Myself in a Kansas Auto Accident Case
Posted in Auto Accidents | Comments Off
March 28th, 2011
When an individual fails to exercise reasonable care to avoid causing emotional injury or intentionally inflicts emotional distress to another, the victim who suffers emotional distress may be able to seek compensation for their injuries. While most states and federal tort law permit a lawsuit based on intentional infliction of emotional distress, many states severely limit the right to recover for negligent infliction of emotional distress. A lawsuit based on the infliction of emotional distress without physical injury generally requires conduct that is extreme and outrageous. When mere insults or trivialities are surpassed, and the conduct of another is regarded as atrocious and beyond the bounds that would normally be accepted by a civilized society, damages may sometimes be available for emotional injury. One such example of inflicting emotional distress would be for someone to falsely inform a husband that his wife had just been killed in a horrendous car accident.
Intentional infliction of emotional distress weighs two factors: (1) The relationship between two or more parties and (2) The susceptibility level of the plaintiff. Infliction of emotional distress is given more weight if the defendant was in a position of authority over the plaintiff, and if the defendant knew the plaintiff would be susceptible and used this knowledge to take advantage and inflict distress in an egregious manner.
A claim of emotional distress may go forward if the following is proven:
- The defendant’s conduct was extreme and outrageous.
- The defendant, through reckless or intentional disregard, caused the plaintiff’s emotional distress.
- It can be proven the plaintiff did indeed suffer emotional distress as a result of the defendant’s reckless disregard.
- The cause of the plaintiff’s emotional distress is directly related to the actions of the defendant.
While virtually all jurisdictions recognize lawsuits based on intentional infliction of emotional distress, many states are far more restrictive when the claim is for negligent infliction of emotional distress. The jurisdiction may require certain specific elements to bring a negligent infliction of emotional distress claim including:
- The emotional distress is a result of physical injury, such as the emotional distress associated with loss of one’s bodily function or disfigurement.
- The person suffers emotional distress from observing a gruesome incident as a bystander.
- The person must be within the “zone of danger” when a close family member is injured so that the plaintiff also could have been injured.
- The action is universally recognized as causing emotional distress, such as misdelivering a death notice or mishandling the corpse of the plaintiff’s love one.
Personal injury that results in intense emotional distress can also be the result of a catastrophic car accident that can leave a victim mentally, physically and emotionally traumatized. Personal injury law may permit an accident victim to file a claim that includes not only economic damages but also non-economic damages like emotional distress. The law generally recognizes emotional distress as a compensable injury. However, the availability of damages for emotional injuries can depend on the type of case and the specific law of your state. It is important to contact an experienced Kansas City personal injury attorney in Kansas or Missouri to obtain legal advice and an assessment of your legal rights.
Your Personal, Professional Team
At a larger law firm, you may feel as though you are just a number among a thousand others. At our friendly and professional law office, we know many critical things—like your name, for starters. At the Law Office of Rodney K. Murrow, we focus on your individual goals to fit your unique circumstances. We prefer this highly personal approach, and we hope that it will suit your needs.
If you have an immediate legal need, please contact Kansas City attorney Rodney K. Murrow’s law office today for a complimentary consultation with an attorney licensed in Kansas and Missouri.
When you need a professional who goes the distance:
The Law Office of Rodney K. Murrow, P.A.
Commerce Bank Building
8700 Monrovia, Suite 208
Lenexa, Kansas 66215
• Phone: 913-492-6200 • Fax: 913-227-0149
A business lawyer & accident injury attorney serving Kansas City, and the surrounding areas of Kansas and Missouri, including but not limited to, Topeka, Lawrence, Independence, Olathe, Overland Park, Liberty, Lee’s Summit, Ottawa, Mound City, Bonner Springs, Atchison, Paola, Emporia, Jefferson City, Salina, Eudora, Columbia, Springfield, Blue Springs, Concordia, Harrisonville, in KS and MO, as well as Wyandotte County, Leavenworth County, Johnson County, Douglas County, Jackson County, Clay County, Franklin County, Miami County, Linn County, Shawnee County, Cass County, Lyon County and Platte County.
Tags: Kansas City personal injury attorney, Personal Injury Claim for Emotional Distress in Kansas City
Posted in Personal Injury | Comments Off
March 4th, 2011
Anti-raiding agreements prevent a departing employee from attempting to hire other employees away from the previous employer. This scenario most commonly occurs when the departing employee is starting their own business or accepts employment with a subsequent employer in which they have hiring authority.
Your Personal, Professional Team
At a larger law firm, you may feel as though you are just a number among a thousand others. At our friendly and professional law office, we know many critical things—like your name, for starters. At the Law Office of Rodney K. Murrow, we focus on your individual goals to fit your unique circumstances. We prefer this highly personal approach, and we hope that it will suit your needs.
If you have an immediate legal need, please contact Kansas City business attorney Rodney K. Murrow’s law office today for a complimentary consultation with an attorney licensed in Kansas and Missouri.
When you need a professional who goes the distance:
The Law Office of Rodney K. Murrow, P.A.
Commerce Bank Building
8700 Monrovia, Suite 208
Lenexa, Kansas 66215
Phone: 913-492-6200
A business lawyer attorney serving Kansas City, and the surrounding areas of Kansas and Missouri, including but not limited to, Topeka, Lawrence, Independence, Olathe, Overland Park, Liberty, Lee’s Summit, Ottawa, Mound City, Bonner Springs, Atchison, Paola, Emporia, Jefferson City, Salina, Eudora, Columbia, Springfield, Blue Springs, Concordia, Harrisonville, in KS and MO, as well as Wyandotte County, Leavenworth County, Johnson County, Douglas County, Jackson County, Clay County, Franklin County, Miami County, Linn County, Shawnee County, Cass County, Lyon County and Platte County.
Tags: Kansas City business attorney, Kansas City Business Law Attorney, What is an Anti-Raiding Agreement?
Posted in Contracts & Agreements | Comments Off
February 23rd, 2011
There are several primary types of restrictive covenants that companies and small businesses will have an experienced business law tourney draft to protect their interests. One of these restrictive covenants is called a non-compete agreement.
Non-compete agreements prevent the departing employees from using the experience and knowledge learned while on the job from starting their own business in direct competition. A non-compete agreement may also protect a business from the damage caused by departing employees leaving their business to work for competitors, vendors or others generally within a specific geographic region and for a specific time period.
If you have an immediate legal need, please call 913-492-6200 to speak with Kansas City business attorney Rodney K. Murrow’s law office today for a complimentary consultation with an attorney licensed in Kansas and Missouri.
Our business law firm serves Kansas City, and the surrounding areas of Kansas and Missouri, including but not limited to, Topeka, Lawrence, Independence, Olathe, Overland Park, Liberty, Lee’s Summit, Ottawa, Mound City, Bonner Springs, Atchison, Paola, Emporia, Jefferson City, Salina, Eudora, Columbia, Springfield, Blue Springs, Concordia, Harrisonville, in KS and MO, as well as Wyandotte County, Leavenworth County, Johnson County, Douglas County, Jackson County, Clay County, Franklin County, Miami County, Linn County, Shawnee County, Cass County, Lyon County and Platte County.
Tags: Kansas City Business Law Attorney, Kansas City Non-Compete Agreement Attorney
Posted in Non-Compete Agreements | Comments Off
February 17th, 2011
Many small business owners opened their business because they had knowledge, skill or perhaps just a keen interest in something and wanted to work for themselves. However, often they quickly learn that there is much more required for running a business than just the knowledge, skill or interest that prompted them to open the business in the first place. How quickly small business owners learn to deal with the legal and business management aspects of running a business can determine whether the business succeeds or fails.
Many years ago in law school, my Corporate Law professor made a comment that has always stuck with me and that I have found to be very true in my 21 years of practicing law. His comment was this:
“If you look at any successful business, you find that they all have on thing in common. The thing they all have in common is that, very early on in their existence, they formed a close relationship with four people: An accountant, a lawyer, a banker and an insurance agent. The reason for that is because it is a problem in one of those four areas that can kill a business just as easily and as often as not making enough money. That’s why large corporations have in-house legal counsel and accounting departments. That’s also why many large corporations self-insure themselves. Small businesses obviously can’t afford to do that, but they can use private attorneys, accountants, insurance agents and banks. And when I say ‘successful business’, you’ll find that this is just as true if the business stayed small or chose to grow. Whether they get that help or choose to try to do it all themselves is often the difference between the business succeeding or failing.”
I have seen my old professor’s statement come true countless times, both for good and bad.
Attorneys help small businesses in the same way that legal departments are used in larger corporations; both help keep the business out of legal trouble. Here are just some of the legal services used by small businesses, in no particular order:
1. Selection and maintenance of a business entity (corporation, partnership, LLC, etc.) as well as helping to draft a business plan, bylaws and operating agreement.
2. Contract drafting or review, including non-compete agreements, vendor contracts, leases, purchase agreements, separation agreements or other types of contracts. It is much cheaper to draft a contract properly to begin with than it is to litigate a poorly drafted contract.
3. Filing, foreclosing and collecting mechanic’s liens and other construction law issues.
4. Commercial or business litigation, whether the business is a plaintiff or a defendant in the lawsuit. This can include breach of contract litigation, suing (or defending a lawsuit) for money owed, business torts (such as interference with contract or business expectation), and obtaining restraining orders preventing further breaches of a contract, enforcing a non-compete agreement or for other reasons.
5. Representing business clients in alternative dispute resolution proceedings such as mediation or arbitration.
6. Representation before public entities such as zoning boards or city councils.
7. Drafting and reviewing employee handbooks for legal compliance and establishing effective employment policies.
8. Representation in various state and federal agencies such as the EPA, state licensing boards, unemployment claims, EEOC, Department of Labor or other entities.
9. Providing cost-effective employment law training to managers, supervisors, HR staff and owners in such areas as sexual harassment, hiring, firing, discrimination, and numerous employment laws.
10. Providing updates regarding changes in the in the law that affect the business which the business might otherwise not know.
11. Insurance coverage disputes.
12. Wage and hour compliance issues under the FLSA and state wage payment laws, including ensuring the correct classification as exempt or nonexempt (sometimes called hourly or salaried) status of employees.
13. Issues unique to not-for-profit corporations.
It usually costs a lot less to prevent a legal problem than it does to fix one after it occurs, and some services can even be handled for flat fees. Just like large corporations consult with their legal departments to prevent or avoid legal problems, so should small businesses with their private attorneys. The key to prevention is not waiting until the crisis occurs. Contacting an attorney for a free initial consultation is essential to discuss what your business might need is far better than waiting until a problem arises.
My goal is first to make sure that your business is protected in order to prevent costly litigation from occurring. If litigation can’t be reasonably avoided, then litigation is pursued aggressively to get the best possible outcome.
Posted in Small Business | Comments Off
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