Writing Samples

Only about 10% of attorneys licensed in Texas practice in federal court. And just a small percentage of that number handle federal appeals. Our firm handles both civil and criminal federal appeals in the United States Court of Appeals for the Fifth Circuit and all other federal circuits.

Examples of our Work

We take a lot of pride in our work and aren't hesitant to compare it to the work of larger firms and government entities. Below are a few samples, along with the competing briefs or motions (all public documents).

United States v. Vaught. Vaught was accused of conspiracy to possess to distribute methamphetamine. He was tried, convicted, and sentence to life without possibility of release. On appeal, we've contested the sufficiency of the evidence, arguing that the government failed to produce evidence of a conspiratorial agreement. The appeal is still pending.

• Vaught Appellate Brief

• Government's Response Brief

• Vaught Reply Brief

• Government's Rule 28(j) Letter

• Vaught's Rule 28(j) Letter

United States v. DeMarquis Williams. DeMarquis Williams was charged with violating 18 U.S.C. § 371 (18 U.S.C. § 1029(a)(2)), Conspiracy to Traffic and Use Unauthorized Access Devices (credit card fraud in layman's terms). He pleaded guilty to the charge, but preserved his rights to appeal his sentence. We handled the appeal in the Fifth Circuit Court of Appeals and obtained a reversal on one of the two issues presented.

• Williams – Appellant's Brief

• Williams - Government's Brief

• United States v. Harris (Williams) – Published Opinion

United States v. Guerrero. Hugo Guerrero was charged with being involved in a conspiracy to distribute a large amount of marijuana and cocaine. His presentence report recommended a prison sentence based on the quantity of drugs involved in the conspiracy. We filed a motion for variance, arguing that the recommended guideline range should be ignored because it didn't adequately consider his minimal role in the offense. Our client was sentenced to the statutory minimum, a material downward departure from the presentence report's original calculation.

• Motion for Variance

• Government Response to Motion for Variance

Federal Jurisdiction Appeal. We sometimes are hired by outside firms to assist with the drafting of motions, memorandum, and briefs. Recently, a well-known firm in the state hired us to draft an appellee's brief on a question of federal jurisdiction. Below is a redacted portion of the brief to demonstrate the kind of work we can do for small, trial law firms. This appeal is still pending.

• Appellee's Brief