Production Problems: Formatting E-Data

ThinkstockPhotos-164446354Producing electronic data in discovery can be complicated by format issues: How do you determine which format to use? Continue reading

Judge’s Advice for Thriving in Complex Litigation

87524559Some civil cases are more complex than others and benefit from direct, intensive judicial management. That’s where complex litigation departments come in: they allow the parties and courts to work together to find practical solutions to the difficult procedural and substantive issues in complex cases. Here’s advice on how to efficiently and effectively handle complex litigation cases from Hon. Richard A. Kramer (Ret.), who presided over cases in San Francisco Superior Court’s Complex Litigation Department until 2015.

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4 Tips for Contention Interrogatories

ThinkstockPhotos-486765445Interrogatories may be the only discovery procedure that can be used to discover a party’s contentions. You can use them to ask an opponent to state whether he or she makes a particular legal contention, to state the factual basis for the contention, and to identify any witnesses or documents supporting the contention. But before you draft your next set of contention interrogatories, review these four tips. Continue reading

Checklist: Moving for Summary Judgment

ThinkstockPhotos-459334539Moving for summary judgment or summary adjudication is a complicated process. You start by considering whether it’s even appropriate to make the motion. Then you review the strict timing requirements. After that comes an evaluation of the pleadings and evidence to support the motion. And then you have to prepare the moving papers. Finally, you schedule a hearing date and serve and file the moving papers. Whew! But it’s not too hard when you follow this handy checklist. Continue reading

Covering Costs in Contingent Fee Agreements

When you’re working for a contingent fee, i.e., you’ll be paid a percentage of the recovery, don’t forget to discuss the payment of costs in your fee agreement with your client. Here’s what you’ll need to include to be sure you cover costs. Continue reading

Moving Tactically: Should You Make a Motion?

465153001Motions are tactical tools, and your decision to seek an order should be made in the context of your overall litigation plan. Always keep in mind that making a motion entails time, effort, and expense for the moving party. Is it worth it? Continue reading

6 Tips for Using Technology in Court Presentations

ThinkstockPhotos-498646267If you’re planning to use electronic technology in your court presentations, such as in your opening statement or closing argument, consider these six tips to make your use of technology as effective as possible while avoiding common pitfalls. Continue reading

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