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How to Prepare the Separate Statement for a Summary Judgment Motion

fingers on keyboard tying out a separate statement in support of a motion for summary judgmentEvery 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

How to Prepare for a Hearing on Summary Judgment

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

How to Shorten or Extend Time for Your Motion

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

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

Is It Too Risky to SLAPP Back?

ThinkstockPhotos-185824314Your client got hit with a Strategic Lawsuit Against Public Participation (SLAPP) suit, i.e., a suit with a cause of action based on your client’s act in furtherance of the constitutional right of petition or free speech in connection with a public issue. You have a chance to hit back with a special motion to strike the cause of action under the anti-SLAPP statute. But should you? Continue reading

Be Ready to Oppose Motions in Limine

474538053In limine motions are a great litigation tool—they get evidence admitted or excluded before it’s even offered. You’ve probably been advised to use them whenever appropriate. But opposing counsel also will have received this advice and will use them against you. Here’s how to respond to opposing counsel’s in limine motion. Continue reading

What Does It Mean to “Meet and Confer” on a Discovery Dispute?

meeting_E013754Before moving to compel discovery responses, California law requires that the parties “meet and confer.” But what do you actually have to do to meet that requirement? Continue reading

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