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
Advice on Jury Instructions and Verdict FormsYou 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 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.