Parental Rights of Non-Biological Parent in Same-Sex RelationshipSame-sex couples are cautioned to seek legal advise from attorneys in the state where they reside who have experience dealing with the uniqu
Evidence "In the Record" vs. Specifically Identifying Evidence in Motion for Summary JudgmentThe 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 CounselThe 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 CounselJury 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 CounselJury instructions provide the jury with the legal structure and guidelines necessary to analyze the evidence and argument presented at trial
Alternative Relief of Amending Pleadings When Faced With Motions to Dismiss and Summary JudgmentIt'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 TrialIn 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 SpecialistIn 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