- 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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