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Did You Know You Can Collect Fees for Time Spent Collecting Fees?

Collecting attorney fee awards and enforcing judgments can be very time-consuming. Don’t forget to collect attorney fees for time spent chasing down your fees in collection efforts. Continue reading

4 Reasons to Get Help on a Fee Motion

Just because you successfully handled the merits of a case doesn’t mean that you should take on a large or complex fee motion that arises from it. It may be time to bring in someone with fee motion expertise. Continue reading

Checklist: What to Do If Summary Judgment Is Denied

You moved for summary judgment but your motion was denied. Here’s a checklist of four things to ask yourself. Continue reading

Dead Man Balking: Writ of Execution Doesn’t Work After Debtor’s Death

thinkstockphotos-501575596So you have a money judgment, but the debtor dies before you can collect. Never mind. You still have a judgment lien on the debtor’s estate. Right? Continue reading

When Should You Cross-Appeal?

ThinkstockPhotos-463518799Missing an opportunity to cross-appeal can be a big mistake. Ordinarily, if you’re on the winning side in the trial court, there’s no need to file a cross-appeal. But there are situations in which filing a cross-appeal is not only appropriate but critical. Continue reading

Cautionary Tale: When a Stipulated Continuance Won’t Save You from Untimeliness

170446161A recent case shows what happened when counsel stipulated to a continuance that took the ruling on a motion to vacate a default judgment past the jurisdictional time limit. It’s the tale of a big win, followed by a crushing loss. And it was an issue of first impression, so arguably counsel couldn’t have seen it coming. Continue reading

Lost on a Motion in Limine? Make Your Record!

The basic rule is that, if you don’t make a timely objection before or when objectionable matters are mentioned or introduced, you may not be able to raise the issue on appeal. See Evid C §353. Accordingly, if you don’t ensure that a proper record is made of any adverse ruling to a motion in limine, you may just have lost a ground for appeal. Here’s how to preserve the ground for appeal when you’re on the losing end of a motion in limine. Continue reading

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