Sarah M. Hayes

Experience

General Litigation

• Defending a wood products manufacturer against actions resulting from a fire on its premises.
• Defending America’s largest generator of electricity from natural gas and geothermal resources in actions resulting from Winter Storm Uri.
• Represented a Fortune 100 healthcare distributor in the Texas state court multi-district opioid litigation in which approximately 50 cases filed by Texas counties have been consolidated. The work consists of case-related research, third-party discovery, offensive discovery strategy, deposition preparation, assistance with expert witnesses and drafting dispositive and non-dispositive motions.
• Represented a restaurant owner and operator in Texas state court multi-district and federal litigation arising out of a nationally reported shootout, including case-related research, assistance with discovery and drafting dispositive and non-dispositive motions.
• Represented former CEO and CFO of a sporting goods company in class action suit alleging violations of federal securities laws, including assistance with discovery and depositions.
• Represented oil and gas company in property dispute. Work consists of case-related research and drafting dispositive and non-dispositive motions.
• Represented the Official Committee of Tort Claimants, the official committee representing the interests of over 70,000 victims of Northern California wildfires in the Chapter 11 reorganization of Pacific Gas and Electric Company and PG&E Corporation. Conducted research, discovery, deposition preparation, and extensive review and analysis of documents for the purpose of claims estimation and determination of nonparty fault. PG&E is the largest bankruptcy case ever filed in California and the sixth largest case ever filed in the U.S.
• Represented a shipping and logistics company in a maritime action involving issues of maritime attachment and vessel arrest. Drafted a motion to dismiss for lack of personal jurisdiction and researched maritime specific issues, including choice of law, forum non conveniens, petitory and possessory, conversion and civil conspiracy.
• Represented a medical holdings company and healthcare services corporation in antitrust litigation. Assisted with the drafting of a motion for summary judgment involving issues of fraud, unfair competition, misappropriation of trade secrets and the Texas Harmful Access by Computer Act.
• Represented an oil and gas company in a case involving issues under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). Conducted research and prepared a memorandum regarding approaches to successor liability under CERCLA, under both the general federal common law and the continuity of enterprise approaches.
• As a member of the BakerHostetler team serving as counsel to the Securities Investor Protection Act (SIPA) Trustee for the liquidation of Bernard L. Madoff Investment Securities LLC (BLMIS), assists with avoidance actions against hedge funds and banks that invested in BLMIS through feeder funds by developing solutions to constitutional and international law issues, drafting complaints and briefs and conducting legal research. Successfully defeated a motion to dismiss.

Labor and Employment

• Successfully obtained summary judgment for a client who specializes in maintenance, modernization and installation work in the power generation industry in an action involving claims of race-based discrimination and retaliation.
• Successfully obtained temporary restraining orders and preliminary injunctions in two actions involving breach of non-competition, non-solicitation and confidentiality clauses for one logistics client.
• Represented an independent merchant bank and its founding members in AAA arbitration brought by former employee alleging association-based disability discrimination, retaliation, violation of Families First Coronavirus Response Act (“FFCRA”), breach of employment and investment agreement, violation of ERISA and constructive discharge. Work consists of drafting pleadings, dispositive and non-dispositive motions and supporting briefing, and conducting case-related research.
• Represented a casualty insurance company in non-compete and non-solicitation clause action against former employee. Work included conducting case-related research, drafting briefing in support of application for temporary restraining order, drafting a motion for expedited discovery and participating in TRO hearing.
• Represented a distribution center against former employee alleging sexual harassment and discrimination. Work consisted of preparing pleadings and discovery and drafting non-dispositive and dispositive motions. Successfully obtained a dismissal of all claims against the client with prejudice.
• Represented a dessert café against two former employees alleging sexual orientation discrimination in highly publicized case. Work consisted of preparing pleadings and discovery, drafting dispositive motions and case-related research. Successfully obtained a dismissal of all claims against the client with prejudice.
• Represented a drilling and production company in FLSA action. Conducted case-related research and assisted in preparation for argument in Fifth Circuit appeal.

Memberships

• Houston Young Lawyers Association
• Houston Lawyers Association
  • Gala Committee (2023)
• The Downtown Group
  • Treasurer (2023)
• Houston Bar Association
  • Diversity, Equity and Inclusion Committee (2021 to 2022)
  • Campaign to End Homelessness and Hunger Committee (2021 to 2022)
• National Bar Association
• Alpha Kappa Alpha Sorority, Inc.

Pro Bono

• Assisted in preparation of executive summary and report of research addressing Barriers to Police Reform and Accountability in Massachusetts.
• Volunteer with Houston Bar Association Legal Lines.
• Assisted on case involving issues of medical malpractice in the armed forces and the Feres Doctrine.