Preparing for Your Hearing

Recently at an MCLE seminar, a sitting judge forewarned the audience that because of all the new judges coming from a variety of backgrounds, often they don’t  have the necessary background on law and procedures for their department. His advice:

come to your hearings with copies of all the important cases and statutes, no matter how basic the concept is.

This sitting judge was subtly saying: Plan on educating the court!!


Continue Reading Know Your Audience

The meet and confer process has failed.  Now you have to decide whether (1) you need to bring a Motion to Compel Further Documents because the documents are an integral part of the defense and/or prosecution of your case, or (2) wait for trial and make a motion in limine to exclude the documents categorically at trial. Two of the factors you are going to have to consider are how much time it’s going to take to prepare the motion as well as the cost to your client.

Most attorneys underestimate the time and cost in filing a Motion to Compel Further Responses.


Continue Reading How Much is that Motion in the Window?