Sylvia H. Walbolt

Sylvia H. Walbolt

Carlton Fields

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Latest Posts › Litigation Strategies

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The Reply Brief: Turning "Getting the Last Word" into "Getting the Win"

When you are the appellant, you always have the burden of persuasion in seeking a reversal. Even on a de novo review, you are starting at least a step behind, psychologically. A reply brief may be the last word and the...more

12/21/2015 - Appeals Litigation Strategies

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

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

Comparison And Contrast: Differing Standards For Inferences In Federal And Florida State Courts

Direct evidence of a matter at issue will not always be available; consequently, civil litigants may sometimes establish facts effectively and conclusively with circumstantial evidence. Nielsen v. City of Sarasota, 117 So. 2d...more

7/9/2013 - Circumstantial Evidence Evidence Evidentiary Rulings Inference Litigation Strategies

Tips For Trial Counsel On Planning, Preparation And Preservation: Creating Defensible Jury Instructions And Planning For A Charge...

Jury instructions are the mechanism that provides the jury with the proper legal structure to analyze the evidence that has been presented at trial. Without proper guidance through good instructions on the law, the jury is...more

2/12/2013 - Charge Conferences Jury Instructions Litigation Strategies Standing Objections

Tips For Trial Counsel On Planning, Preparation And Preservation

Litigants settle lawsuits and claims every day, for a multitude of different reasons, including purely economic ones. Litigation is costly and, as a practical matter, it may be better to pay something to make a claim go away...more

12/19/2012 - Admissions Evidence Litigation Strategies Settlement

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