• Creating Your Complaint Post Twombly and Iqbal
  • Rule 12 Motions
    • Why They Matter
    • What to do About Them
    • Drafting Tips
    • What to Watch Out For
    • Responses
  • The Answer (to the complaint!)
  • Case Scheduling and the Case Management Conference
  • Discovery & E-Discovery
    • Rule 26—Scope of Discovery and Privilege Issues
    • The Tools of Discovery—Rules 33-36
    • Dealing with Discovery Disputes/Sanctions
    • E-discovery —overview and recent developments
  • Depo Strategies
    • Deciding Whom to Depose
    • Taking Good Depositions
    • Making Effective Use of Depositions at Trial
  • Ex Parte Motions & Injunctive Relief Injunctive Relief
  • Oral Argument Tips
    • Why it Still Matters
    • What Judges Hate/Want
    • Practitioner Prep – how to prepare properly
    • Tips and Mistakes Not to Make
    • What to do if a Tentative Has Been Issued
    • Being Persuasive
  • Expert Witnesses / Expert Reports
    • Recent Changes to FRCP Regarding Experts
    • Expert Reports
    • Expert Depositions
    • Daubert Motions
    • Presenting Experts at Trial
  • Drafting and Replying to Motions for Summary Judgment
  • Heading to Trial
    • Trial Briefs
    • Pretrial Statement
    • Pretrial Conference and Order (FRCP 16)
  • Pre-Trial Matters
    • Client & Witness Preparation
    • Your Jury Questionnaire and Voir Dire Tips
    • Jury Instructions – pitfalls & best practices
    • Jury Verdict Forms – pitfalls & best practices
    • Motions in Limine
  • Trial Presentation
    • Opening Statements
    • Introduction of Exhibits
    • Direct and Cross-Examinations
    • Evidentiary Objections
    • Closing Arguments

 

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