Closing Arguments: Focus and Organization
Closing Argument: Opportunity and Challenge
How to Make Clear, Quick and Effective Objections
More on Cross-Examination: Building a Case Brick by Brick
Podcast - Cross-Examination: Don't Ask One Question Too Many
Podcast - The Ten Commandments of Cross-Examination
Making the Lawyer-Client Relationship Work in Challenging Litigation – Speaking of Litigation Video Podcast
The Presumption of Innocence Podcast: Episode 42 - AI in Criminal Justice: Opportunity or Opportunity for Misuse?
Podcast - Refresh vs. Impeach: Know the Difference
Consumer Finance Monitor Podcast Episode: Universal Injunctions, Associational Standing, and Forum Shopping - Their Effects on Legal Challenges to Regulations
Podcast - Impeaching with a Deposition
Podcast - Cross-Examination of Expert Witnesses
Cross-Examination: The Three C’s of Impeachment
Cross-Examination: How to Effectively Impeach with a Prior Inconsistent Statement
Cross-Examination: Finding Control
Podcast - Cross-Examination: Don't Argue - Elicit Facts
Cross-Examination: Asking the Right Leading Questions
AGG Talks: Home Health & Hospice - Lessons Learned From ALJ Hospice Audit Appeals
Prelude to the Business Court and 15th Court of Appeals: More Questions Than Answers | Tyler Talbert | Texas Appellate Law Podcast
Podcast - Cross-Examination: The Importance of Organization
Litigating in Florida state court can be a slog. Cases move slowly, discovery can be a hassle, and scheduling is sometimes a headache. Yet judges aren’t to blame—Florida trial courts are overloaded and under-resourced. ...more
When Can I File An Appeal? The short answer to this question is that, in most cases, you can only file an appeal from a final judgment. P.B. § 61-1; State v. Curcio, 191 Conn. 27, 30 (1983) (“The statutory right to...more
Restricted Appeals A restricted appeal is a direct attack on a judgment. To be entitled to a restricted appeal, an appellant must demonstrate several elements described below. ...more
Appellate practice can be challenging - In complicated cases, it's made all the more challenging by the word limits often imposed by the pertinent rules of procedure. For example, in the North Carolina Court of Appeals,...more
The Florida Legislature recently amended Florida Statutes section 26.012 and, in so doing, eliminated circuit court jurisdiction over most county court appeals. Effective January 1, 2021, most county court rulings will now be...more
Previously, I have written about appellate decisions considering the issues presented by pro se litigants and their non-compliance with applicable trial and appellate court rules. (See July 9, 2018 blog and September 18, 2018...more
In January 2020, the Florida Supreme Court adopted three subtle, but significant changes to the Florida Rules of Appellate Procedure: Rule 9.130(a)(3)(C) was amended to clarify language regarding nonfinal orders denying...more
Florida Supreme Court rewrites the rules, lifting restrictions on the immediate appeal of orders denying absolute, qualified, or sovereign immunity. For those who have kept abreast of the latest opinions issued by the...more
Impact of Amendments to Florida Rule of Appellate Procedure 9.130 and Florida Highway Patrol v. Jackson on Governmental Entities and Employees If you are a State Agency, City, County, Sheriff’s Office, School Board, Police...more
During my tenure as a judicial clerk on the U.S. Court of Appeals for the Ninth Circuit, I found the most misused element of appellate practice to be submissions of supplemental authority under Federal Rule of Appellate...more
The Appellate Court: An exciting forum of oral advocacy; a check on the process and the decisions of our trial courts; a second chance for parties to make their case; and a place where novel and important legal principles...more
How do we, the legal paraprofessionals, build a consistent, reliable bridge between the attorney and the clerk, while delivering our pleadings through the Court's gatekeepers? ...more
The time for appealing from an order, whether final or non-final, is typically jurisdictional. If the appellant or petitioner misses the applicable deadline, the appellate court lacks jurisdiction to review the order on...more