Christopher Paolino

• Assisted in jury trial in breach of contract and tortious interference case between two banks before the Supreme Court of New York, Commercial Division, including preparing opening and closing statements, direct and cross-examinations, motion for directed verdict, bench memos, evidentiary objections, demonstrative exhibits, deposition excerpts for unavailable witnesses, exhibit and witness lists, jury instructions, and jury verdict sheet.
• Conducted the direct examination of fact witness in misappropriation of trade secrets arbitration on behalf of broker-dealer client, addressing trade secret status of client lists and laying factual predicates for damage model.
• Successfully briefed and argued before the Supreme Court of New York, Appellate Division, First Department, in opposition to an appeal from a decision and order denying a motion for leave to amend. See Crossbeat New York, LLC v LiiRN, LLC, 169 A.D.3d 604 (1st Dep’t 2019).
• Drafted appellate briefs and second chaired argument before the Supreme Court of New York, Appellate Division, First Department, which overturned jury verdict on breach of contract claim, resulting in $3.7 million benefit to client.
• Drafted appellate brief before the California Court of Appeal, 2nd Appellate District, Division 7, which ruled in favor of plaintiff-client and affirmed denial of anti-SLAPP motion in breach of contract case.
• Successfully briefed collateral source and prejudgment interest accrual issues before the Supreme Court of New York, Commercial Division, and the Supreme Court of New York, Appellate Division, First Department, and second chaired arguments before both courts, resulting in approximately $4.2 million benefit to defendant-client.
• Conducted depositions of fact witnesses in a variety of cases, including a breach of contract dispute involving a broker-dealer’s breach of a fully disclosed clearing agreement, a fraudulent inducement dispute arising out of a $35 million asset sale, and a breach of partnership dispute involving a $30 million oil and gas venture.
• Successfully briefed and argued before the Supreme Court of New York, Commercial Division, in connection with a motion to dismiss.
• Successfully negotiated settlement at mediation, limiting client’s exposure to only 0.2% of damages sought in New Jersey case.
• Drafted successful motions and oppositions, including, inter alia: (1) a motion to vacate entry of default and opposition to a motion for default judgment based on the plaintiff’s failure to properly effectuate service of process under New Jersey law; (2) a motion for temporary restraining order and preliminary injunction, enjoining misappropriation of trade secrets under Connecticut law; (3) opposition to a motion for summary judgment in a foreclosure action against a bank in connection with multimillion-dollar loans issued to finance the operations of oil and gas wells in North Dakota and Montana; (4) a motion demanding a trial by jury under North Dakota law, despite loan documents’ inclusion of jury waiver provisions; and, (5) various motions in limine to exclude evidence at trial.

*Certain representative experiences occurred prior to joining Dorsey