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Non-Testifying Litigation Consulting

Understand the File Before It Controls the Case.

Ami helps counsel reconstruct title and escrow transactions, identify the records that matter, test theories early, and prepare focused discovery and depositions without committing first to a testifying expert.

Ami Hadad, title and escrow litigation consultant
Early Case Evaluation

Operational Context Before Discovery Hardens

A title or escrow file can contain hundreds of pages while the decisive sequence turns on a small number of instructions, exceptions, communications, and disbursement records. Ami helps counsel identify that sequence early.

01

Case Theory Review

Evaluate whether the alleged conduct fits the transaction record, the role of the title or escrow professional, and the claimed standard.

02

Record Prioritization

Identify missing instructions, title documents, communications, ledgers, payoff records, closing files, and internal procedures.

03

Transaction Timeline

Reconstruct who knew what, when conditions changed, how instructions were handled, and where the file diverged.

Discovery and Deposition Strategy

Ask Better Questions Because You Understand the Operation.

Counsel often knows the legal theory before knowing how a title or escrow office would have processed the transaction. Ami translates operational practice into focused discovery requests and deposition topics.

The goal is not to replace legal strategy. It is to help counsel recognize the records, terminology, workflow, and decision points that can confirm or undermine a case theory.

Opposing Expert Review

Test the Opinion Against the Actual File

Ami can review an opposing report or declaration for unsupported assumptions, omitted records, role confusion, inconsistent timelines, and opinions that do not match operational reality.

Scope and Foundation

Does the opinion address the actual assignment, relevant transaction, and role of the party being evaluated?

Record Completeness

Were material instructions, amendments, title records, communications, or disbursement records overlooked?

Operational Accuracy

Does the described workflow reflect how title and escrow functions are actually performed in the relevant market?

Causation Assumptions

Does the opinion connect the alleged departure to the claimed outcome, or simply identify a different preferred practice?

Transaction Consulting for Active or Troubled Closings

When a closing is stalled or disputed, Ami can provide operational guidance concerning the closing sequence, written instructions, title requirements, exception schedules, document flow, and communications among the parties.

This service is advisory. Ami does not provide legal representation, make coverage determinations, or replace the title company, escrow holder, broker, lender, or counsel handling the transaction.

Common assignments

  • Reviewing escrow instructions and amendments for operational clarity
  • Explaining title commitment requirements and exception schedules
  • Identifying missing closing records or unresolved process steps
  • Helping a party prepare focused questions for its lawyer, title company, or escrow officer
  • Providing a neutral operational perspective before a dispute escalates

Need an Operational Read on the File?

Send a brief, nonprivileged summary and identify the question counsel needs answered first.