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Library of California Employment Law Forms

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David Lowe, John Mullan


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Practical Guidance for Employment Lawyers in California: Library of California Employment Law Forms, created by attorney experts in Employment Law, offers 650 pages featuring over 115 sample documents in print and on CD in word form for simple drafting and editing. The forms may be edited to suit the unique facts and circumstances of each case. The book includes everything a lawyer needs throughout the litigation process, including demand letters, complaints, discovery requests, as well as the documents necessary for trial and appeal.

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  • Availability: Available
  • Brand: The Recorder (CA)
  • Product Type: Books
  • ISBN: 978-1-57625-562-9
  • Pub#/SKU#: CAEMP

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  • David Lowe
David Lowe a partner at Rudy, Exelrod, Zieff & Lowe, LLP, is consistently recognized as one of the top employment lawyers in California and has received the California Lawyer Attorney of the Year (“CLAY”) Award for “extraordinary achievement” in employment law.  He has served as Chair of the Bar Association of San Francisco Labor & Employment Section and Chair of the International Bar Association Discrimination Law Committee. He specializes in international employment cases, complex litigation, and executive severance negotiations, as well as litigation and negotiation of individual employment law claims, including claims for wrongful termination, harassment, discrimination, whistleblower retaliation, unpaid commissions and bonuses, breach of contract and violation of the WARN Act, military leave, family/medical leave and wage and hour laws.


Author Image
  • John Mullan
John Mullan an attorney at Rudy, Exelrod, Zieff & Lowe, LLP, has been a contributing author on several amicus briefs pertaining to wage and hour matters filed on behalf of the National Employment Lawyers Association, the National Employment Law Project, and the AFL-CIO. In addition, Mr. Mullan is a Supervising Attorney for the Workers’ Rights Clinic of the San Francisco Legal Aid Society-Employment Law Center, and has spoken on employment law issues for the Employment Law Center. Since August 2010, Mr. Mullan has been a contributor to the Fair Labor Standards Act treatise published by the American Bar Association Section of Labor and Employment Law.

Chapter 1 New Client and Intake Forms
1-001 Welcome Letter to New Client with Retainer Agreement
1-002 Contingency Fee Retainer Agreement — Individual
1-003 Contingency Fee Retainer Agreement — Class Representative
1-004 Hourly Retainer Agreement
1-005 Co-Counseling and Fee Sharing Agreement with Client Consent
1-006 Joint Representation and Conflict Waiver
1-007 Medical Records Release Authorization
1-008 Letter Requesting Personnel File and Wage Records
1-009 Rejection Letter to Potential Client

Chapter 2 Pre-Litigation Forms
2-001 Department of Fair Employment and Housing Complaint
2-002 California Government Tort Claim
2-003 Preservation of Evidence Letter
2-004 Demand Letter
2-005 Tolling Agreement

Chapter 3 Complaints
3-001 Complaint — Breach of Contract
3-002 Complaint — Wrongful Termination in Violation of Public Policy
3-003 Complaint — Miscellaneous Tort Claims (Assault, Battery, False Imprisonment, Intentional Infliction of Emotional Distress)
3-004 Complaint — Fraud and Related Claims
3-005 Complaint — Defamation and Related Claims
3-006 Complaint — Invasion of Privacy
3-007 Complaint — Fair Employment and Housing Act Violations (Gender Discrimination, Sex Harassment and Retaliation)
3-008 Complaint — Fair Employment and Housing Act Violations (Age Discrimination)
3-009 Complaint — Fair Employment and Housing Act Violations (National Origin Discrimination and Retaliation)
3-010 Complaint — Fair Employment and Housing Act Violations (Race and Disability Discrimination, Wrongful Termination in Violation of Public Policy)
3-011 Complaint — California Family Rights Act Claims
3-012 Complaint — Unruh Act Civil Rights Violations
3-013 Complaint — Labor Code Violations (Wage Violations)
3-014 Complaint — Labor Code Violations (Retaliation)
3-015 Complaint — Private Attorneys General Act Claims
3-016 Complaint — Unfair Competition Law Claims
3-017 Complaint — Class Action Allegations

Chapter 4 Discovery Forms
4-001 Interrogatories (Wage and Hour)
4-002 Interrogatories (Age Discrimination)
4-003 Interrogatories (Disability Discrimination)
4-004 Interrogatories (Breach of Contract)
4-005 Interrogatories (National-Origin Discrimination)
4-006 Request for Admissions (Wage and Hour)
4-007 Request for Production of Documents (Age Discrimination)
4-008 Request for Production of Documents (Wage and Hour)
4-009 Request for Production of Documents (Disability Discrimination)
4-010 Request for Production of Documents (Breach of Contract)
4-011 Request for Production of Documents (National-Origin Discrimination)
4-012 Notice of Deposition
4-013 Notice of Deposition — Person Most Knowledgeable
4-014 Deposition Subpoena for Non-Party
4-015 Deposition Subpoena Duces Tecum
4-016 Notice of Deposition (Expert Witness)
4-017 Letter to Witness Forwarding Deposition Subpoena
4-018 Supplemental Interrogatories
4-019 Supplemental Request for Production of Documents
4-020 Motion to Issue a Commission for Out-of-State Discovery
4-021 Letter to Client Regarding Discovery Requests
4-022 Answers to Interrogatories
4-023 Responses to Requests for Production of Documents
4-024 Objections to Notice of Deposition
4-025 Meet and Confer Letter Regarding Discovery Dispute
4-026 Demand for Expert Witness Disclosure
4-027 Expert Witness Disclosure and Declaration

Chapter 5 Motions
5-001 Demurrer
5-002 Motion to Strike (Slapp)
5-003 Motion to Amend Complaint
5-004 Motion to Compel Further Discovery Responses
5-005 Motion for Protective Order
5-006 Motion to Seal Pleadings
5-007 Stipulated Protective Order
5-008 Motion to Quash Subpoena for Consumer (Employment) Records
5-009 Motion to Quash Subpoena for Medical Records
5-010 Motion for Class Certification
5-011 Motion for Summary Judgment
5-012 Separate Statement in Support of Motion for Summary Judgment
5-013 Opposition to Motion for Summary Judgment
5-014 Response to Separate Statement in Support of Motion for Summary Judgment
5-015 Motion for Judgment on the Pleadings
5-016 Stipulation to Continue Hearing Date
5-017 Motion for Trial Plan
5-018 Motion to Continue Trial Date
5-019 Motion in Limine (Example 1)
5-020 Motion in Limine (Example 2)
5-021 Motion in Limine (Example 3)
5-022 Motion in Limine (Example 4)
5-023 Motion for Judgment Notwithstanding the Verdict
5-024 Motion for New Trial
5-025 Request for Dismissal
5-026 Motion for Award of Attorneys’ Fees and Costs
5-027 Motion to Tax or Strike Costs

Chapter 6 Trial Forms
6-001 Letter to Witnesses Regarding Trial Date
6-002 Letter Enclosing Trial Subpoena
6-003 Notice to Appear At Trial
6-004 Witness List
6-005 Jury Questionnaire
6-006 Voir Dire Questions
6-007 Plaintiff’s Jury Instructions (Proposed)
6-008 Verdict Form—General
6-009 Verdict Form—Special
6-010 Plaintiff’s Request for Statement of Decision
6-011 Plaintiff’s Proposed Statement of Decision
6-012 Judgment
6-013 Memorandum of Costs

Chapter 7 Settlement Forms
7-001 Notice of Settlement
7-002 Confidential Settlement Agreement and General Release of Claims

Chapter 8 Class Action Forms
8-001 Notice of Class Action
8-002 Motion for Preliminary Approval of Class Action Settlement
8-003 [Proposed] Order Granting Plaintiffs’ Motion for Preliminary Approval of Class Action Settlement
8-004 Notice of Class Action Settlement
8-005 Opt-Out Form
8-006 Claim Form
8-007 Motion for Final Approval of Class Action Settlement
8-008 [Proposed] Order Granting Approval of Class Action Settlement

Chapter 9 Federal Forms
9-001 Federal Government Tort Claim
9-002 Fair Labor Standards Act Collective Action Complaint
9-003 Rule 26(a) Initial Disclosures
9-004 Rule 30(b)(6) Notice of Deposition
9-005 Motion for Class Certification
9-006 Motion for Conditional FLSA Collective Action Certification, Approval of Hoffman-La Roche Notice
9-007 Hoffman-La Roche Notice
9-008 Consent to Join Lawsuit as a Party Plaintiff
9-009 Rule 56 Motion for Partial Summary Judgment