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Unforced Errors: Don't Leave a Ground of the Court's Ruling Unchallenged

We have previously explained the importance of appealing every aspect of a trial court's order granted on multiple, independent grounds. The Eleventh Circuit recently reminded us of that, but also that in opposing motions at...more

Tips For Preserving The Record: The “Opening The Door” Opportunity And The Art Of The Proffer

Trial courts make evidentiary rulings both before and during trial, and trial lawyers should be alert to the opportunity to request the court to revisit its earlier rulings during the course of trial. ...more

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

Tips For Trial Counsel On Planning, Preparation, And Preservation: The "Opening The Door" Opportunity And The Art Of The Proffer

Trial courts make evidentiary rulings both before and during trial, and trial lawyers should be alert to the opportunity to request the court to revisit its earlier rulings during the course of trial. See Persaud v. State,...more

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