All Rights Reserved. For this month s column, I solicited practice tips from all my friends and colleagues. The list below, which is not in any particular order, and includes tips for civil litigation, transactions, appeals and general law practice, probably contains something you can use. Don t forget to re-designate trial counsel when you send in your Trial Information Statement. When sending the other party a draft that you have revised, always show the revisions, include a copy that does, or explain them all in a cover letter.
Blind revisions are unfair.
The judge doesn t want to have to compare lists, wade through your entire request, or cross-examine you at argument. When you move for more specific answers to Interrogatories, make it clear to the Court what was not answered and what you want. Don t make the Court read the whole set and guess. Save copies of all e-mails sent and received as part of the correspondence for a file. At the appellate level the Statement is limited to two pages and may not contain footnotes.