Parental Rights of Non-Biological Parent in Same-Sex Relationship
Same-sex couples are cautioned to seek legal advise from attorneys in the state where they reside who have experience dealing with the uniqu
Biological Father's Parental Rights
The Florida Supreme Court clarified that a biological father is entitled to rebut the common law presumption that a mother's husband is
Post-judgment Discovery to Collect a Federal Money Judgment
What is the deadline under Florida law for completing post-judgment discovery for the purpose of collecting a federal money judgment issued
No Loss of Consortium Damages For Death of Spouse Resulting From Injury Prior To Marriage
May a spouse who was not married to the decedent at the time of the decedent’s injury recover consortium damages as part of a wrongful death
Default On Liability Does Not Equate To Liability For All Damages.
You start celebrating (or lamenting) because the judge granted the motion to default the defendant. But then you pause to figure out what th
Friends Matter: Amicus Makes The Difference
The benefit of amicus or friend of the court briefs on appeal is often debated. Do they present another opportunity for the parties to repac
Evidence "In the Record" vs. Specifically Identifying Evidence in Motion for Summary Judgment
The key to a successful motion for summary judgment or the opposition thereto (and keeping a favorable ruling on appeal) is the identificati
Verdict Forms: Tips for Trial Counsel
The instructions to the jury are a framework for the verdict form. The verdict form, in turn, formalizes the jury’s decisions on the case, t
The Jury Charge Conference: Tips for Trial Counsel
Jury instructions and the verdict form are the keys a jury needs to unlock the proper analysis of the evidence and argument at trial, render
Drafting Jury Instructions: Tips for Trial Counsel
Jury instructions provide the jury with the legal structure and guidelines necessary to analyze the evidence and argument presented at trial
Advice on Jury Instructions and Verdict Forms
You have been asked to prepare a set of jury instructions and a verdict form for trial . . . . What do you do? Where do you start? And what
Alternative Relief of Amending Pleadings When Faced With Motions to Dismiss and Summary Judgment
It's not uncommon to seek leave to amend as an alternative form of relief in opposition to a motion to dismiss or for summary judgment.
The Perils Of Relying On A Co-Defendant's Objections At Trial
In a case involving multiple defendants, each party making its own objection to each piece of evidence can create an inefficient and tedious
About This Blog: The Next Level - Advice From An Appellate Specialist
In my blog, I share the expected: tips on preservation of error during litigation and at trial. I also share tips on drafting those jury ins
