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©2016 By Cristina Alonso, P.L.L.C. 

July 22, 2019

Same-sex couples are cautioned to seek legal advise from attorneys in the state where they reside who have experience dealing with the unique issues that arise when same-sex couples decide to form a family and raise children and that it is not advisable to rely on co-p...

July 2, 2018

The Florida Supreme Court clarified that a biological father is entitled to rebut the common law presumption that a mother's husband is the legal father of a child born to an intact marriage, notwithstanding the mother or her husband's objection.

February 26, 2018

What is the deadline under Florida law for completing post-judgment discovery for the purpose of collecting a federal money judgment issued by a federal court in Florida?

May 5, 2017

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 suit?

March 27, 2017

You start celebrating (or lamenting) because the judge granted the motion to default the defendant. But then you pause to figure out what that means for the claimed damages. Is causation deemed established for purposes of establishing damages? Can the plaintiff’s damag...

February 9, 2017

The benefit of amicus or friend of the court briefs on appeal is often debated. Do they present another opportunity for the parties to repackage their arguments or are they truly friend of the court briefs that give the appellate court broader insight into the practica...

January 6, 2017

The key to a successful motion for summary judgment or the opposition thereto (and keeping a favorable ruling on appeal) is the identification of evidence or the lack thereof.  State Farm Mutual Insurance Co. v. Figler Family Chiropractic, P.A., illustrates this point.

December 1, 2016

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, telling us how it will answer the claims and defenses. Its structure and language could influence the jury’s ultimate answers. It...

November 15, 2016

Jury instructions and the verdict form are the keys a jury needs to unlock the proper analysis of the evidence and argument at trial, rendering the jury charge conference a critical aspect of any successful trial strategy.

November 1, 2016

Jury instructions provide the jury with the legal structure and guidelines necessary to analyze the evidence and argument presented at trial. Without proper guidance through good instructions on the law, the jury is not as likely to get it right. So, jury instructions...

October 4, 2016

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 does this have to do with appellate practice? Here, we offer some basic guidelines for drafting jury instructions and a verdict f...

September 20, 2016

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. But to preserve that right to amend for appellate review, some jurisdictions require that you specify how the pleading would be a...

September 1, 2016

In a case involving multiple defendants, each party making its own objection to each piece of evidence can create an inefficient and tedious trial. Trial counsel may feel compelled to rely on another party’s already-made objection rather than repeat an objection and po...

August 31, 2016

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 instructions and verdict forms you tend to leave to the last minute and on how to deal with that charge conference, not to mention o...

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