Should You Use Tactical Dismissals?

84215043As plaintiff’s counsel, you always want to analyze how best to present your client’s case in the most efficient and persuasive way. Sometimes doing that means dismissing certain parties or causes of action. But such tactical dismissals aren’t without risk. Here’s a list of questions to ask yourself when deciding whether or not to dismiss. Continue reading

5 Things to Do to Prepare for Voir Dire

78724287When next faced with preparing for jury voir dire examination before trial, consider these five practical suggestions. Continue reading

8 Things to Consider Before Opposing a Motion to Consolidate

532203529In response to a plaintiff’s motion for consolidation, the court can combine two or more separately filed lawsuits for simultaneous disposition. This promotes efficiency, but there are very big downsides for a defendant in a consolidated case. Here are 8 things defense counsel should consider when faced with a motion to consolidate.

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Come Together? 10 Things to Consider Before Moving to Consolidate

515961369Consolidation can be a useful efficiency technique because it allows the court to combine two or more separately filed lawsuits for simultaneous disposition. This efficiency is not without danger—consolidation may produce an incomprehensible case that the jury can’t handle fairly or understand.

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Tentative Rulings: Contest or Concede?

200368976-001When the tentative ruling is against you, you’ve got two choices: contest or concede. Here’s the spoiler: One of these choices is generally the way to go. Continue reading

Should You Make an In Limine Motion?

procon_153899206The next time you’re deciding between excluding evidence via a motion in limine or taking your chances at trial, make sure to review this chart of the pros and cons of motions in limine. Continue reading

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

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