What’s NOT Protected by Attorney-Client Privilege?

The attorney-client privilege (Evid C §§950–962) protects a client from disclosure of confidential communications between attorney and client. But not every communication between attorney and client is protected. Do you know what’s not covered? Continue reading

2 Reasons to Go for Defendant’s Default

ThinkstockPhotos-158687666A default occurs when a defendant served with a complaint doesn’t file the appropriate response within the time allowed. CCP §§585–586. After a defendant is in default, a plaintiff may file a request for entry of default and then apply for a default judgment. Here are two practical reasons to seek entry of default and default judgment. Continue reading

Prepare for Case Management Conferences in 4 Steps

ThinkstockPhotos-477805217In the past, most California superior courts routinely held trial-setting, pretrial, arbitration status, and status conferences. Delay reduction rules put a stop to this practice, consolidating all of these into a comprehensive conference that occurs in the first 180 days after the complaint is filed. Cal Rules of Ct 3.721. And woe to any attorney who comes to the conference unprepared! Take some of the stress out of preparing for your next case management conference by using these four steps. Continue reading

Phone It In: How to Appear by Telephone

ThinkstockPhotos-101720876Want to avoid traffic, parking, and court security checkpoints? Appear at a hearing by telephone! Continue reading

Take 5 (Steps) Before Moving for Summary Judgment

five_108523216Thinking of filing a summary judgment motion in your case? Take the time to follow these five steps in assessing whether this is the right move to make. Continue reading

Develop a Routine: Stock Questions to Ask in Every Deposition

185496686Every case is different, but there are some questions you should ask in most every deposition. Know your routine questions and use them. Continue reading

12 Must-Do Tasks Before Cross-Examination

Few attorneys have the time or budget to do detailed preparation for cross-examination of every witness. And even if the budget makes it possible, time spent on other aspects of trial preparation will force counsel to take shortcuts. When time is short, these 12 tasks are the bare minimum necessary for cross-examination preparation. Continue reading

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