In the News

Haynes and Boone Appellate Lawyers Achieve Victory in San Antonio Court of Appeals

A team of Haynes and Boone, LLP lawyers successfully represented Keystone-Texas Property Holding Corporation in an appeal arising out of a failed sale of the Marriott Rivercenter Hotel. >>



Polly Graham

Associate

Houston


1221 McKinney Street
Suite 2100
Houston, 77010
T +1 713.547.2570
F +1 713.547.2600

Áreas de Practica

Educación

  • J.D., Harvard Law School, 2008, cum laude, Journal on Legislation, Supervising Editor
  • B.S., Chemistry, Brown University, 2004, magna cum laude, with honors

Bar Admissions

  • Texas, 2009

Court Admissions

  • U.S. Court of Appeals for the Fifth Circuit
  • U.S. Court of Appeals for the Ninth Circuit
  • U.S. Court of Appeals for the Eleventh Circuit
  • U.S. District Court for the Southern District of Texas

Judicial Clerkships

Law Clerk for Judge R. Lanier Anderson, Eleventh Circuit Court of Appeals

After graduating from Harvard Law School, Polly Graham served as a law clerk to Honorable R. Lanier Anderson on the Eleventh Circuit Court of Appeals where she assisted the court in preparing for oral argument and analyzing complex legal questions. Ms. Graham also gained experience in effective appellate advocacy while interning in the office of the Solicitor General of Texas, the chief appellate lawyer for the State of Texas.

Today, she draws on these experiences to assist clients at the trial and appellate level in both state and federal court. Her experience includes: 

  • Working on appellate briefs to the Fifth Circuit and the Texas appellate courts.

  • Advocating an oral argument.

  • Drafting jury charges, formulating charge objections and assisting in preparation for charge conferences.

  • Working with trial teams to draft dispositive motions in the trial court, including motions for summary judgment and judgment notwithstanding the verdict.

Selected Representative Experience


HMC Hotel Properties II, LP v. Keystone-Texas Property Holding Corp., No. 04-10-00620-CV, 2011 WL 5869608, (Tex. App.–San Antonio Nov. 23, 2011).
In an appeal arising out of a commercial real estate dispute, persuaded the San Antonio Court of Appeals (1) to affirm an approximately $50 million judgment in favor of our client, and (2) in a cross-appeal, to reinstate the jury's $7.5 million punitive damages award that the trial court had declined to incorporate into the judgment.

LHC Nashua Partnership, LTD v. PDNED Sagamore Nashua, LLC, 659 F.3d 450 (5th Cir. 2011)
Won reversal of a $25.5 million jury award in which the Fifth Circuit vacated the damages for alleged lost profits arising out of a contract concerning the transfer of rights to purchase shopping mall property.

Main v. Royall, No. 05-09-01503-CV (Tex. App.-Dallas July 25, 2011)
Represented amicus curiae in an interlocutory appeal obtaining reversal of the trial court’s order denying summary judgment on defamation claims against two media defendants regarding the book, Bulldozed: 'Kelo,' Eminent Domain and the American Lust for Land.

Jesco v. Hess, No. 2009-45089 (165th Dist. Ct., Harris County, Tex.) (May 2011)
Assisted trial team in preparing and arguing a jury charge, directed verdict motion, and all post-verdict briefing in the trial of a construction law dispute that resulted in a favorable defense verdict on all claims.

Minnis v. Citrin Holdings, No. 2006-78939 (133rd Dist. Ct., Harris County, Tex.)
In a real estate partnership dispute, assisted plaintiff's trial counsel with post-trial briefing and formation of judgment issues in connection with the entry of $54.6 million judgment in favor of our client.

Barnes v. Stone Way Limited Partnership, 330 S.W.3d 925 (Tex. App.--Beaumont 2011, no pet.)
In a pro bono representation, obtained reversal of a default judgment evicting a low-income tenant from her apartment by persuading the court of appeals that the trial court abused its discretion in denying the tenant's motion for a new trial.

Westergren v. National Property Holdings, L.P., No. 2008-36847 (269th Dist. Ct., Harris County, Tex.)
Argued jury charge and persuaded the trial court, through a motion for judgment notwithstanding the verdict (JNOV), to set aside the jury's multi-million dollar verdict and enter a take nothing judgment in a real estate dispute involving claims for breach of contract, fraud and breach of partnership duties.

In the Matter of Asarco L.L.C., Cause No. 09-41259 (5th Cir. 2010)
Persuaded the Fifth Circuit Court of Appeals to dismiss the appeal of a $3.6 billion bankruptcy plan of reorganization, which was challenged by a competing bidder and the company's union.

H. v. C. (S.D. Tex.-Houston Div. 2010)
Won a take-nothing summary judgment to defeat a multi-million dollar claim alleging breach of fiduciary duty and breach of contract based on a claim that a joint venture existed between the parties.

HMC Hotel Properties II Ltd. Partnership v. Keystone-Texas Property Holding Corp., No.05-CI-14229 (166th Dist. Ct., Bexar County, Tex.)
In a commercial real estate dispute, assisted trial team with strategy, legal briefing, and preparing and arguing the jury charge in a trial that resulted in a favorable judgment of approximately $50 million.

United States ex rel. Abbott v. BP P.L.C., BP America, Inc., BP Exploration and Production, Inc.
Representation of BP in United States ex rel. Abbott v. BP P.L.C., BP America, Inc., BP Exploration and Production, Inc. (S.D. Tex.), a False Claims Act qui tam suit involving allegations of false certifications of compliance with regulations governing defendants’ offshore oil and gas leases in the Gulf of Mexico.

Online Publications

09/01/2011 - Fifth Circuit Civil Appellate Update
As seen in The Appellate Advocate, State Bar of Texas Appellate Section Report, Fall 2011, Vol. 24, No. 1.

04/01/2011 - Texas Supreme Court Update
As seen in The Appellate Advocate, State Bar of Texas Appellate Section Report, Winter 2010, Vol. 23, No. 2.