Should You Move for Mistrial?

90279590Certain things that happen during trial may be so improper and prejudicial that they deprive a party of the right to a fair trial. That’s when counsel may move for a mistrial. But just because you can doesn’t mean you should. Like everything else at trial, whether to move for mistrial is a tactical decision. Continue reading

Keeping Tabs on a Bad Neighbor

484190499When a conflict arises between neighbors, attorneys often recommend that their clients keep a record of events. A written log of dates and times is one thing, but a video or audio recording can easily step over the line from keeping tabs to violating privacy rights. Continue reading

Costs Claimed Out of Whack? Move to Tax Them

507797495To the victor go the spoils. But that doesn’t mean the prevailing party can get whatever it wants in claimed costs. If you disagree with the costs listed in the prevailing party’s costs memorandum, file and serve a motion to tax costs. Here’s how. Continue reading

4 Preliminary Questions for Every Deposition You Take

185496686Before you get to the substantive questions, make sure to ask these four important preliminary questions in every deposition you take. Continue reading

Coordinate Your Discovery Methods

466206411Often you can use more than one discovery method to get the same facts or evidence. You can take a pick-and-choose approach to your methodology, or better yet, use a coordinated approach that aims multiple discovery methods at the same evidence.  Continue reading

Be Ready to Oppose Motions in Limine

474538053In limine motions are a great litigation tool—they get evidence admitted or excluded before it’s even offered. You’ve probably been advised to use them whenever appropriate. But opposing counsel also will have received this advice and will use them against you. Here’s how to respond to opposing counsel’s in limine motion. Continue reading

5 Tips to Make the Most of Requests for Admission

463413901Requests for admission are very valuable yet underutilized tools. They’re one of the best techniques to create admissible evidence for summary judgment and trial—make good use of them! Continue reading

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