Need More Time to Oppose a Summary Judgment Motion?

Once you receive a summary judgment motion filed against your client, you have about two months to file and serve your opposition papers. That sounds like plenty of time, but it may not be sufficient to marshal the evidence you need to oppose the motion. That’s when you need a continuance. Continue reading

6 Sources to Use When Preparing Voir Dire Questions

As you work on your questions to ask the jurors during voir dire, consider these six sources for ideas. Continue reading

Need Another Expert? Here’s How to Augment Your Expert Designation

When you need another expert to support your client’s case or there’s a change in the general substance of a  previously designated expert, you’ll need to move to augment or amend your expert witness declaration. Continue reading

New Year, New Laws for Civil Litigators

The California legislature has enacted new laws that may affect your litigation practice. Here are some of the key statutory changes you need to know about. Continue reading

The Do’s and Don’ts of Building Your Case with Social Media Info

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

What to Do a Month Before Trial

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

When Can You Discover Private Information?

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.

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Have You Considered a Motion in Limine to ADMIT Evidence?

young lawyer considering whether to use a motion in limine to include evidenceMany 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

Checklist: Summary Judgment Motion Deadlines

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

Get a Crash Course from Your Expert

Learn fast from your expert about the area of expertiseSome 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