The following is a guest blog post by Renee Galente Stackhouse. Renee is the founder and trial lawyer at Stackhouse, APC, where she focuses on plaintiff’s personal injury and military defense in San Diego. She is the immediate past President of California Women Lawyers, President of the CWL Foundation, Chair of the CLA SSF Section, and sits on the Board of the San Diego County Bar Association.
You would be surprised how easy it is to find public information on the Internet. Or maybe you wouldn’t, given the many stories of jobs lost and cases jeopardized by social media posts. Using Google and social media searches on parties and witnesses can be very helpful to your case, but make sure you don’t overstep. Continue reading
You’re 30 days from your trial date. Maybe it’s been a while since you’ve gotten this close, or maybe it’s your first time. Don’t worry—here’s a handy chart setting out what you need to do. Continue reading
Even when a litigant can’t assert a statutory privilege, private matters may nonetheless be protected from discovery under the constitutional right of privacy. Balancing the privacy interest at stake against the need for discovery has always been a difficult task. But a recent California Supreme Court case, Williams v Superior Court (2017) 3 C5th 531, has clarified the proper analysis to use.
Many lawyers view motions in limine as tools used only to exclude or limit particular evidence. But the experts know that a motion in limine is also a useful tool to admit evidence. Continue reading
Summary judgment and summary adjudication motions are the most difficult and time-consuming motions that can be filed with the court. Use this checklist to make sure that you meet the key deadlines. Continue reading
Some lawyers decide at the beginning of a case that they’ll never be able to understand what the expert is talking about, and they make no effort to do so. Bad plan! Regardless of the expert’s skill, it’s the lawyer’s responsibility to make sure that his or her expertise is presented to the trier of fact in an admissible and persuasive way. To do that, the lawyer needs to understand the expert’s testimony and field of expertise. Here are four ways to educate yourself fast. Continue reading
Every motion for summary judgment or summary adjudication must include “a separate statement setting forth plainly and concisely all material facts which the moving party contends are undisputed.” CCP §437c(b)(1). Here’s what to include in a separate statement and how to format it. Continue reading
Motions for summary judgment and summary adjudication are frequently made in the alternative. Do you know why this is and when not to move alternatively? Continue reading
A hearing on a motion for summary judgment or summary adjudication presents opportunities you don’t want to miss. Here’s how to prepare for the hearing whether the tentative ruling is in your favor or not, and when there’s no tentative ruling at all. Continue reading
The timing on making motions is both a procedural and a tactical matter. Sometimes you’ll need a hearing date that’s sooner than would be normally possible, and other times you’ll want to file a notice of motion or get a hearing date that’s after the last date allowed. Here’s how to get the timing to work for you. Continue reading