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

Which Summary Judgment Document Do You Draft First?

452028697When it comes to preparing a summary judgment motion, many attorneys prepare the supporting documents in the same order each time (and instruct new attorneys to do so, too). But one order may not fit all cases.

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5 Rules to Minimize Expert Contamination

181587139Attorneys risk expert contamination when they provide information to an expert about a case. Although you need to discuss the case candidly and openly with your expert, you don’t want to contaminate the expert with information on the case’s weaknesses and problems. Five simple rules will help you minimize the risk of unnecessarily imparting harmful information to your expert. Continue reading

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