Construction Insurance
Resume:
Timothy Eric Headley
Rockwall, TX 75032
214-***-**** (cell), ***.*******@*********.***
PROFESSIONAL EXPERIENCE
Cozen O’Connor, Dallas, TX, 2003 to 2011
General responsibilities: A ll aspects of litigation, including, but not limi ted to:
i nvestigation of claims and defenses; draft wri t ten discovery and responses;
conduct depositions of fact and expert witnesses; work closely with experts and
corporate representatives on li tigation strategy; draft motions for summary
j udgment and other pleadings; report to clients; attend mediations; negotiate
settlements; and attend t r ial if case could not be settled.
Construction law experience: E xtensive representation of various contractors
and subcontractors involved in commercial construction defect li tigation.
P roduct liability experience: Representation of various manufacturers being
sued for personal injuries allegedly caused by their products. Many of these
cases involved alleged injuries caused by exposure to chemical products.
I nsurance law experience: Defense of carriers involved in coverage lit igation.
A lso actively involved in rendering coverage advice, opinions and in representing
i nsurers in connection with first- and thi rd-party coverage-related li tigation.
A reas of concentration in coverage matters include: fi rst-party claims involving
t he insuring agreement and the applicabili ty of exclusions to coverage; defense of
carriers in fi rst-party claims involving mold, hail and various other types of
p roperty damage. Extensive experience handling coverage disputes involving the
d uty to defend and/or indemnify under liability policies, especially in the area of
t hird-party construction defect li tigation. Also represented insurers in defense of
claims of common law and statutory bad faith; disputes among multiple or
successive insurers for latent injuries/property damage; disputes among primary,
excess and umbrella carriers; business in terruption coverage disputes; and claims
for coverage by entities claiming additional insured status.
Personal inju ry experience: Defense of individuals and entities in personal
i njury li tigation arising from on-the-job accidents, t ransportation accidents, and
p remises liability cases.
Touchstone, Bernays, P.C., Dallas, Texas, 2001 to 2003
I nsurance law experience: Defense of carriers in fi rst-party property claims
i nvolving the insuring agreement and applicabili ty of exclusions to coverage;
coverage disputes involving duties to defend and/or indemnify under general
l iability insurance policies; construction defect claims; defense of carriers from
claims of common law and statutory bad faith. Also provided coverage opinions
regarding coverage afforded under auto liabili ty policies.
Personal inju ry experience: Defense of individuals and entities in personal
i njury li tigation arising from on-the-job accidents, t ransportation accidents, and
p remises liability cases.
Phillips & Akers, P.C ., Houston, Texas,1998 to 2001
Construction law experience: E xtensive representation of various contractors
and subcontractors involved in commercial construction defect li tigation.
Personal inju ry experience: Defense of individuals and entities in personal
i njury li tigation arising from on-the-job accidents, t ransportation accidents, and
p remises liability cases.
Oil/Gas experience: Representation of drilling company in personal injury
defense cases.
I nsurance law experience: Defense of carriers in fi rst-party property claims
i nvolving the insuring agreement and applicabili ty of exclusions to coverage;
coverage disputes involving duties to defend and/or indemnify under general
l iabili ty insurance policies; construction defect claims; defense of carriers from
claims of common law and statutory bad faith.
EDUCATION
South Texas College of Law, Houston, Texas. Awarded Doctor of Jurisprudence in May 1998.
Finished in the upper 20% of my class; Dean’s List, Spring of 1998; received speaking award in the
Leroy Jeffers Memorial Intramural Moot Court Competition; made the highest grade in my
Constitutional Law class.
Southeastern Paralegal Institute, Dallas, Texas. Awarded Post Graduate Paralegal Certificate in
July 1991. Approved by the American Bar Association GPA 4.0 (Honor Graduate)
Texas Tech University, Lubbock, Texas. Awarded Bachelor of Arts Degree in August 1990.
Major course of study: Political Science. Minor: Speech Communication GPA 3.4
PUBLICATIONS
Author, Primary and Excess Coverage, Covering Key Policy Provisions and Exclusions, University
of Houston Law Foundation. October 2005, April 2007, June 2008. Included presentations at CLE
course.
Author, When is Recovery of Mental Anguish Damages Allowed?, Touchstone Bernays Legal
Update, Fall 2001.
Author, Does Fort Worth Ever Cross Your Mind?: What a Plaintiff Must Prove in Order to Hold a
Corporation Liable for Exemplary Damages, Phillips & Akers Law Report, March 2000.
Contributor, Insurance Coverage Newsletter, Texas Association of Defense Counsel, Fall 1999
through Spring 2001.
ACCOMPLISHMENTS
Obtained summary judgment in favor of an insurer in a duty to defend case involving 26
underlying lawsuits filed against the insured for defective EIFS siding.
Negotiated a very favorable settlement in favor of an insurer in coverage litigation involving a $20
million property loss stemming from alleged cell phone theft.
Successfully defended a company involved in product liability litigation brought by over 200
plaintiffs claiming to have suffered personal injuries from exposure to the company’s chemical
product. Obtained dismissal without paying any money to the plaintiffs.
Obtained summary judgment in favor of a manufacturer of temporary buildings in litigation
brought by a plaintiff claiming to have suffered personal injuries from mold exposure in a building
manufactured by the company.
Successfully defended a company involved in wrongful death case by obtaining a dismissal after
filing a summary judgment motion based upon lack of medical causation evidence. Paid
absolutely no money to the plaintiff.
Obtained summary judgment in favor of insurer against additional insured over settlement made by
additional insured in a construction defect case.
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