Andrew Clay

Bio as of June 2018:

Andrew Clay assisted in the preparation of this article. He is a litigation paralegal at Rains Lucia Stern St. Phalle & Silver, PC. He works on all aspects of case development, focusing on drafting discovery, motions, and other pleadings.

Articles written by this author:

Prying attorneys from their deceptive clients

The crime-fraud exception to attorney-client privilege can be a powerful tool to pry out defendant’s secrets and separate the defendant from its former attorneys

Eustace de Saint Phalle
Andrew Clay

2010 December


Don’t let defendants Sargon your experts

“…But courts must also be cautious in excluding expert testimony. The court must not weigh an opinion’s probative value or substitute its own opinion for the expert’s opinion.”

Eustace de Saint Phalle
William Veen
Andrew Clay

2013 June


Unrelated medical issues can hurt your case

Don’t let defense counsel use unrelated medical issues to distract the jury and embarrass your client

Eustace de Saint Phalle
Andrew Clay

2015 January


Vocational rehab examination by the defense

Don’t agree to any sham demand for a vocational exam of your client by a defense expert

Eustace de Saint Phalle
Andrew Clay

2017 May


How to win at mud wrestling

Closing argument is the defense’s last chance to smear you and your client. Be ready!

Eustace de Saint Phalle
Andrew Clay

2017 July


Defending your treating physician’s opinion testimony

If your treating doc will testify as to causation, don’t let the defense torpedo the testimony

Eustace de Saint Phalle
Andrew Clay

2017 November


How to maximize your client’s recovery in a workers’ compensation credit hearing

How to maximize your client’s recovery in a workers’ compensation credit hearing

Proving employer fault for the injury can offset the WC credit against your recovery – and you can be paid for your work as an expert witness on damages

Eustace de Saint Phalle
Andrew Clay

2018 July


Dealing with the Cuevas decision

Regarding future medical costs, the appellate court overlooked the uncertainty of health insurance in the future

Eustace de Saint Phalle
Andrew Clay

2018 October