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Litigation Strategies Evidence Objections

Kerr Russell

Five Tips for Preparing to Testify at a Deposition

Kerr Russell on

Preparing for a deposition can be challenging whether it is a person’s first or hundredth time testifying under oath. Being questioned frequently causes anxiety. But the experience does not have to be so daunting with...more

Carlton Fields

Quick Trial Checklist

Carlton Fields on

This chart provides a quick reference regarding motions and objections that may be made immediately prior to, during, and immediately after trial to preserve issues for appellate review. ...more

Carlton Fields

A Former Appellate Court Judge Offers Tips to Trial Attorneys

Carlton Fields on

While trial attorneys know they must preserve issues they wish to raise on appeal, they often overlook the basic steps required to help ensure appellate review. During more than 27 years on the bench, former Florida appellate...more

Carlton Fields

Be Wary About A Trial Court's Assurances of Preservation

Carlton Fields on

Imagine a trial judge is trying to move things along at a charge conference. An issue arises, trial counsel begins to voice objections, and the judge short-circuits the discussion by saying, “Your rights are saved on the...more

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