Matthew Conigliaro

Matthew Conigliaro

Carlton Fields Jorden Burt

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Proffers 101: When to Make Your Offer of Proof

Where a party challenges a trial court’s ruling excluding testimony, appellate courts generally require the substance of the excluded evidence to have been set forth on the record or else the challenge will not be properly...more

5/4/2015 - Appellate Review Offer of Proof Termination

Pre-Trial Problems: Summary Judgment & Evidentiary Rulings

The Fifth Circuit’s decision in Blessey v. Marine Services, Inc., --- F.3d ---, 2014 WL 5837059 (5th Cir. Nov. 10, 2014), highlights two different ways that adverse pretrial rulings can wind up unreviewable. ...more

12/8/2014 - Appeals Evidentiary Rulings Motions in Limine Rule 50 Summary Judgment

Pitfalls Of The Verdict Form And The Two-Issue Rule

1. Florida’s “two-issue rule” generally holds that an appellant cannot show reversible error when an error relates to one claim or defense and the verdict does not reveal whether the appellee prevailed on that basis or...more

11/11/2013 - Appeals Jury Verdicts Reversible Error Two-Issue Rule

23 Tips For Improved Jury Instructions

Jury instructions are important in winning the case before the jury. They can also provide grounds for appeal if errors are properly preserved. The following points address the most common problems we appellate lawyers see...more

8/30/2013 - Appeals Jury Instructions Litigation Strategies Objection Procedures

10 Appellate Commandments For Trial Lawyers

1. Always bring appellate counsel into the case before trial. If the case is important enough to try, it almost certainly will be important enough for the loser to appeal. 2. Always, at the very least, involve...more

8/27/2013 - Litigation Strategies

New Twists On Florida’s ‘Tipsy Coachman’ Doctrine

A recent Florida appellate decision examines some new twists on Florida’s “tipsy coachman” doctrine. Before we discuss the new decision, though, it may be useful to discuss what the tipsy coachman doctrine is and where it...more

8/27/2013 - Appeals Trial Court Orders

22 Tips For Improved Jury Instructions

Jury instructions obviously are important in winning the case before the jury. ...more

8/8/2013 - Judges Jury Instructions Litigation Strategies Objection Procedures

Florida Supreme Court Approves Standard Jury Instructions For Use In Contract And Business Litigation

On June 6, for the first time, the Florida Supreme Court approved standard jury instructions for use in contract and business litigation. ...more

6/10/2013 - Breach of Contract Contract Formation Contract Interpretation Damages Jury Instructions

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