Jennifer Morales

Claggett & Sykes

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I’m a native of Las Vegas, Nevada where I was raised in a single parent household with no siblings. My mother worked as a blackjack dealer for over thirty years. I have so many memories of my mom struggling to provide for us. As a child, I dreamed that one day, I would show my mother that all her sacrifices had a purpose. I believe this upbringing made me resilient and motivated me to push through my failures and become successful.

I’ve always been fascinated with the medical field and considered applying to medical school. However, there was one minor problem with that plan: I have a VERY weak stomach. I quickly realized that I needed a career that didn’t involve blood, guts, or bodily fluids.

I started working in law firms during high school. I held nearly every position in a law office before I completed college. The more that I learned about the law, the more I wanted to continue learning. I eventually quit working at law firms so that I could pursue my bachelor’s degree full time. By the time I earned a bachelor’s degree in criminal justice with an emphasis in psychology, I had been a victim of two armed robberies. After those experiences, I wanted to become a District Attorney and help prosecute violent offenders. It seemed like a solid plan until I accepted an extern position at the District Attorney’s Violent Crimes Division. My job included reviewing witness statements, photographs of heinous crimes, and seeing firsthand the evil in this world.

I quickly rerouted my path and accepted a position at one of the largest civil defense firms in town. It was at this firm that my interest in medicine merged with my fascination with the law. I was placed in a group at the firm that primarily defended medical malpractice and nursing home cases. I also defended slip and falls, car wrecks, product defects, and trucking accidents. However, more than half of my practice was defending medical providers.

Overall, I liked civil practice, but I wanted to help those who had been injured. I never liked being on the defense; most of the time it was a thankless job. With a few exceptions, I never felt like I was on the right side. I recall leaving depositions of family members of people who had been catastrophically injured and feeling horrible that I was defending someone who I knew was liable. Yet, it never seemed like the right time to jump to the other side. However, after a few personal experiences of watching my own family suffer at the hands of medical providers, I knew that I needed to use my knowledge to start helping people who have been injured. It was time to take the risk (as the financial provider of my family) and make the jump.

In 2014, I started working with Claggett & Sykes law firm. I quickly realized that this is exactly what I’m supposed to be doing. For the first time in my career, I was no longer searching for what I should do next. I am exactly where I am supposed to be, and I can remain solely focused on getting better at my practice and defending victims. My only regret is not jumping to the Plaintiff’s side sooner. However, we all realize in this journey of life that sometimes we need to understand “why.” My experience has allowed me to thoroughly understand why I love what I do.

In my spare time, you will find me spending time with my husband and four children. Specifically, we love traveling, boating, playing golf, snorkeling, taking part in martial arts, and making every holiday extra special. I also enjoy spending time with my friends whom I consider an extended family. Many of my friends are my partners and employees at Claggett & Sykes. To say that I’m living beyond my wildest dreams is an understatement.

Shannon Wise · Jennifer Morales · Brian Blankenship · Jim Murphy · Sean Claggett

Managing the Case and Putting Constant Pressure on the Defense

Drafting Complaints

• Frame the Case with Purpose. Not just about Notice.
• Know your audience.
• Name All Parties.
• Separate Claims.
• Plead All Damages.
• Plead Punitive Damages.
• Be aware of specific rules for wrongful death cases.
• Tell the Story from the Defendant’s wrongful conduct.
• Plead jurisdictional facts to avoid removal.
• Uses at Trial.
• Don’t let it sit. File early.

Draft Jury Instructions and Written Discovery

• Figure out what you have to prove.
• Draft RPDs first and before the discovery period begins so they are ready to go the moment you can send discovery.
• Save the Rogs and Admissions. Throw darts with these.

Review Initial Disclosures and immediately determine what you did not get.

• Don’t sit on it and be lazy.
• Did you get insurance policies? All of them?
• Did you get a list of witnesses who can be deposed?
• Did you get color photos?
• Did you get actual documents rather than BS.

Send Letter regarding Disclosures and insurance policies. (always incomplete).

Send Written Discovery First Day Possible.

• Ask for policies and procedures.
• Add another request for insurance.
• Ask for all video and audio.
• Ask for the Claims File.
• Ask for Prior Incidents.
• Work out any issues with a protective order. If they want one, you need a draft before discovery begins because you are likely to challenge it. Don’t just sign them. Make them file a motion. Work this out as early as possible.

Review Discovery Upon Receipt

• Review Responses.
• Did you get a privilege log? Does it comply with applicable law?
• Did you get complete responses?
• Did you get color photos?
• Did you get video?
• Are the objections boilerplate? Always will be. This is not permitted in most or all jurisdictions.
• Defense attorneys are taught to not respond and lazy lawyers tolerate it.

Prepare Good Faith Letter or Schedule Call.

• Some states require a letter. If so, do it within days of receipt of responses. Good practice to do one anyway.
• Send letter and schedule a conference. Don’t leave it open ended. You give them 3 dates. If they do not respond, you call on all 3 of those dates.
• Have your good faith conference and give a short, but reasonable time for a supplement.

File your Motion to Compel.

• You will be filing these. It’s not if, but when. Get the Court on notice early about Defense games.
• Get an Order for more documents.
• If the production is still not satisfactory, then prepare a motion for an order to show cause.