Harold E Franklin Jr.

Mr. Franklin’s recent practice includes:

• Taking and defending the depositions of fact witnesses (including corporate representatives) and expert witnesses;
  
  
• Being individually selected by multi-national corporation to conduct analysis of its document retention policy, including various litigation holds, and to provide a recommendation to the corporation regarding proposed revisions to its policies;
  
  
• Coordinating and supervising team of attorneys and support staff to review automotive products litigation and pre-suit files to produce documents, pursuant to a court order, under extreme time constraints;
  
  
• Preparing briefs in support of various motions, including:
  
  
  • Various Motions for Summary Judgment;
    
    
  • Motion to compel based on the spousal privilege and the psychiatrist-patient privilege under Georgia law;
    
    
  • Motion to Dismiss pending arbitration;
    
    
  • Various Motions to Compel and Responses to Motions to Compel involving various complex discovery disputes;
    
    
• Presenting opening statements and conducting settlement negotiations at mediations in complex high-stakes litigation and pre-suit matters;
  
  
• Oral argument of numerous pre-trial evidentiary motions; and
  
  
• Oral argument in opposition to non-settling co-defendant’s motion to amend answer to assert a cross-claim for equitable indemnification.

In addition, Mr. Franklin has utilized his fluency in Spanish in his law practice in matters in Puerto Rico, Europe and South America. These matters have included:

• Played active role in time sensitive and highly complex corporate internal investigation of a European energy company after it restated its oil and gas reserves. Translated and analyzed key documents and provided analysis and assessment on various corporate issues;
  
  
• Played active role in expert depositions involving complex product liability action. Prepared analysis of deposition proceedings, directed negotiations and secured global settlement; and
  
  
• Conducted review of trial and appellate record and prepared analysis of legal issues involving multi-billion dollar corporation regarding disputes over contractual terms and licensing agreements.