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

Motion to Compel = Motion of Last Resort

One young man pull other oneThe other side is not giving you adequate discovery responses. In frustration, you may want to file a motion to compel. But stay calm and consider carefully whether doing so really makes sense and if there are better alternatives. Continue reading

Drafting a Summary Judgment Order

465058199Yay! Your client prevailed on a summary judgment motion! But now you have to draft the proposed order. Do you know what to do? Here’s some help. Continue reading

Why Choose Federal Court?

177130937When you have a case that may be filed in either California state court or in federal court, you need to give some thought to selecting a forum. Why would you want to go to federal court? Continue reading

Mini Opening for Voir Dire

jdopening_12384583As they say, never miss a chance to make a good first impression. If the judge permits it, take the opportunity to address prospective jurors before the oral questioning phase of the voir dire has begun. There are many advantages to the mini-opening statement and little downside.  Continue reading

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