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
You moved for summary judgment but your motion was denied. Here’s a checklist of four things to ask yourself. Continue reading
Juries usually base their verdicts on a small number of crucial points. But lawyers tend to offer as much evidence as possible, believing this will make their case more convincing or fearing they’ll leave something out. Finding the fine line between making sure the point isn’t lost and losing the point by insulting jurors with repetition requires thought and preparation. Here are six methods for streamlining the evidence in your next trial. Continue reading
When considering whether to move for summary judgment or summary adjudication, always assess whether there are better procedures available for narrowing the issues or terminating the litigation. Keep the following chart handy to help you compare summary judgment and adjudication motions with alternative dispositive motions available under California law. Continue reading
Thinking of filing a summary judgment motion in your case? Take the time to follow these five steps in assessing whether this is the right move to make. Continue reading
When it comes to preparing a summary judgment motion, many attorneys prepare the supporting documents in the same order each time (and instruct new attorneys to do so, too). But one order may not fit all cases.
Yay! Your client prevailed on a summary judgment motion! But now you have to draft the proposed order. Do you know what to do? Here’s some help. Continue reading
It’s easy to fall into the trap of not nailing things down in deposition as well as you thought you did. Check out one expert’s advice for getting the deposition testimony you’ll need for your summary judgment motion. Continue reading