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Post-judgment Discovery to Collect a Federal Money Judgment

No Loss of Consortium Damages For Death of Spouse Resulting From Injury Prior To Marriage

Default On Liability Does Not Equate To Liability For All Damages.

Friends Matter: Amicus Makes The Difference

Evidence "In the Record" vs. Specifically Identifying Evidence in Motion for Summary Judgment

Advice on Jury Instructions and Verdict Forms

About This Blog: The Next Level - Advice From An Appellate Specialist

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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.

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