Dean Morande

Dean Morande

Carlton Fields Jorden Burt

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Latest Posts › Litigation Strategies


How to Properly Join in a Co-Party’s Brief or Motion to Avoid Waiver Issues

Joining in a co-party’s brief or motion can be cost effective, but the careful litigator should make sure to explain to the court how the other party’s arguments apply to your client. Failure to do so may result in waiver, as...more

11/20/2015 - Federal Rules of Appellate Procedure Litigation Strategies Waivers

What Exactly Was Excluded? Proffering Expert Opinions to Preserve Daubert/Frye Challenges

Most practitioners would agree that, if the court excludes an expert based on a Daubert challenge—and that is the only expert opining on a subject—then in most instances there should be no need to proffer the expert’s...more

6/17/2015 - Appeals Causation Daubert Standards Evidentiary Rulings Expert Testimony Expert Witness Fire Insurance Insurance Litigation Litigation Strategies Motion To Strike

Strategies In Class Action Engagement: Complimentary Roles Of Inside And Outside Counsel

This continues our series of blog posts on effective partnering between inside and outside counsel to defend against class action lawsuits. Inside and outside counsel should have different but complimentary roles in...more

10/14/2013 - Class Action Class Certification Corporate Counsel Litigation Strategies Outside Counsel

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