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
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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
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
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
The Next Level - Advice From An Appellate Specialist
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