Sarah M. Hayes

Experience

General Litigation

• Involved in defense of 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.
• Involved in representation of 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.
• Involved in representation of 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.
• Involved in representation of oil and gas company in property dispute. Work consists of case-related research and drafting dispositive and non-dispositive motions.
• Assisted in the representation of 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 United States.
• Assisted in the representation of 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.
• Assisted in the representation of 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.
• Assisted in the representation of the Trustee in the liquidation of Bernie L. Madoff Investment Securities LLC, in connection with Madoff’s Ponzi Scheme. Conducted review and analysis of discovery in support of affirmative defenses.
• Assisted in the representation of 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.

Labor and Employment

• Involved in representation of 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.
• Assisted in representation of 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.
• Assisted in representation of 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.
• Assisted in representation of 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.
• 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.
• Assisted in representation of 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 Bar Association
  • Diversity, Equity and Inclusion Committee: 2021-2022
  • Campaign to End Homelessness and Hunger Committee: 2021-2022
• 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.