5 Things to Do Before Deposing an Expert

92419672Taking the deposition of an opponent’s disclosed expert entails more and different preparation than when you’re deposing a lay witness. Here are 5 things to do when prepping for an expert’s deposition. 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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Put Chambers Chat on the Record

117533578Right before the trial begins, trial judges routinely invite counsel into chambers to explore areas of agreement and disagreement, anticipated trial objections, and how certain matters will be handled at trial. These conversations may feel informal, but they are far from it—get any argument or decisions made in chambers on the record. Continue reading

Does Litigating Make Economic Sense?

465153001One of the most important factors to consider when taking a case is whether the cost of litigating is likely to outweigh the gain. Even if the potential clients are willing to pay your fee, you may better serve them by saying “No.” Continue reading

Are Two (or More) Experts Better Than One?

sb10063567v-001Should you hire multiple experts on the same topic? There are some very good reasons to use this strategy. Continue reading

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