• Lead counsel on appeal: serve as lead counsel in appellate courts across the State of Texas and in the Texas Supreme Court.
  • Co-counsel on appeal: we are also available to serve as co-counsel and provide advice and support at all stages of an appeal.
  • Collaboration on briefs: review and provide additional content on already prepared briefs.
  • Permissive Appeal: evaluate ability to obtain permissive appeal and prepare motions for permissive appeal in the trial and appellate courts.


  • Draft petitions for writ of mandamus: provides a unique perspective on petitions for writ of mandamus via Lorien Whyte’s long-time experience at the appellate court as the mandamus attorney. Also available to prepare the accompanying mandamus record and emergency motions to stay that are often necessary.
  • Evaluate availability of mandamus relief: provide analysis of whether mandamus relief can and should be sought in a given case.

Advanced Litigation Support

  • Trial strategy: provide analysis of causes of action and elements necessary to succeed in prosecuting or defending a case to aid in early strategy and developing the record for appeal.
  • Jury Charge preparation: prepare and argue jury charge at trial.  However, preparation of the jury charge at the start of a suit can aid trial counsel in identifying key legal issues and the necessary evidence to be successful at trial.
  • Motions for Summary Judgment: prepare motions for summary judgment and responses regarding difficult legal issues. Also available to consult on already prepared motions and responses.
  • Preservation of issues in advance of appeal: aid trial counsel in preserving vital issues for appeal.
  • Research and brief legal issues: with extensive experience in appeals, and in particular researching and drafting opinions in the court of appeals, Lorien Whyte is able to conduct expansive research and brief and argue key legal issues prior to and during trial.
  • Pleas to the Jurisdiction, Venue Rulings, and Special Appearances: some rulings early in a case commonly lead to appeals in the appellate court. Early involvement can aid in thoroughly preparing the issues in preparation for appellate review.

Amicus Support

  • Prepare amicus briefs for clients that are not parties to an appeal but that may be impacted by the outcome of a pending appeal.