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
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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
The Next Level - Advice From An Appellate Specialist
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