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Summary Judgment Litigation Strategies Evidence

Baker Botts L.L.P.

Diligence Over Delay: Texas Supreme Court’s Recent Decision Highlights the Risks of Discovery Deferral

Baker Botts L.L.P. on

Raoger Corp. v. Myers, No. 23-0662 (Tex. Apr. 11, 2025) – one of the Texas Supreme Court’s most recent opinions on the summary judgment standard – highlights the importance of diligent discovery practices and the potentially...more

Gray Reed

Using Evidence to Fill Gaps in Pleadings Silent on Important Coverage Facts

Gray Reed on

A decision out of the United States District Court for the Southern District of Texas showcases the practical challenge in the relationship between workers’ compensation and the pleading standards required to trigger...more

Mintz - Intellectual Property Viewpoints

Trade Secret Owners Need to Find the Facts Instead of Letting the Facts Find Them

Recent case law confirms that trade secret owners should proactively investigate any suspicions of theft, and if they do not, they may be at greater risk of being barred under the statute of limitations than they may expect....more

Minerva26

Why Skipping Initial Disclosures Can Cost You the Case

Minerva26 on

Litigators, take note—Rule 26(a) is not just a box to check in the early stages of discovery. Failing to comply with its initial disclosure requirements can have disastrous and expensive consequences, as U.S. Bank recently...more

Freiberger Haber LLP

Res Judicata Barred Subsequent Action To Quiet Title Because It Involved Essentially The Same Causes of Action As Asserted In An...

Freiberger Haber LLP on

Previously, this Blog examined the doctrine of res judicata (here, here, here and here). Under the doctrine, a party may not litigate a claim where a judgment on the merits exists from a prior action between the same parties...more

McDermott Will & Emery

Sour Grapes: Attorney’s Oral Agreement Might Be Okay if Fair, Just, and Fully Advised

McDermott Will & Emery on

The US Court of Appeals for the Ninth Circuit found that a district court erred in declaring on summary judgment that an attorney had no ownership interest in a winery because the alleged agreement was made orally. The Ninth...more

Farrell Fritz, P.C.

A Cautious Reminder When Responding to a Rule 19-a Statement of Material Facts on a Motion for Summary Judgment

Farrell Fritz, P.C. on

Although discretionary, it is well-known among commercial practitioners that the Commercial Division justices generally like a Rule 19-a statement of material facts included with the submission of a summary judgment motion....more

Constangy, Brooks, Smith & Prophete, LLP

Robin's quickie guide to motions to dismiss, summary judgment, and trial

What's the difference? There are three main ways for a defendant to bring a lawsuit to an end. Each involves a different level of proof – and of expense and hassle. It's better to get a lawsuit “disposed of” as early as...more

Farrell Fritz, P.C.

The Proof Is in the Note: Commercial Division Holds a Heter Iska is Not Outside Proof for Purposes of Summary Judgment in Lieu of...

Farrell Fritz, P.C. on

As many practitioners are aware, the litigation process in New York often feels like a tortoise race, with many cases taking years to resolve. Section 3213 of the CPLR (“Summary Judgment in Lieu of Complaint”) is a bit of an...more

Jackson Lewis P.C.

Amendment To Florida Rules Increases Likelihood Of Summary Judgment In State Court

Jackson Lewis P.C. on

The Florida Supreme Court recently amended Florida Rule of Civil Procedure 1.510 (Summary Judgment), adopting the less restrictive federal summary judgment standard as articulated by the United States Supreme Court in Celotex...more

Burr & Forman

Florida Supreme Court Amends Summary Judgment Procedural Rule to Mirror Federal Doctrine

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Florida courts have required the moving party to “conclusively disprove” the nonmovant’s theory of the case in order to eliminate any issue of fact, whereas the federal doctrine permits the entry of summary judgment when...more

Rumberger | Kirk

New Year, New Florida Summary Judgment Standard

Rumberger | Kirk on

It’s Time to Adapt Your Litigation Strategy to a More Flexible Summary Judgment Standard - On the final day of 2020, the Florida Supreme Court waived adieu to the past in two related decisions on the summary judgment...more

Carlton Fields

Preserving Arguments: Playing “Hide the Ball” Can Be Costly

Carlton Fields on

A state high court recently issued a stark reminder to litigants of their duty to clearly bring to the court’s attention the arguments and evidence upon which they rely in order to both survive summary judgment and preserve...more

Troutman Pepper Locke

The Nuts And Bolts Of Local Practice In The Eastern District Of Michigan (Part 2) - A Guide To Practicing In The U.S. District...

Troutman Pepper Locke on

As in the Michigan state court system, most of your time in a federal civil case will be spent on discovery, and most of your interaction with the court will be through motion practice. Different courts have different rules...more

Carlton Fields

The Game of Forfeiture: Fumbling the Ball and How the Court May Recover It

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In the spirit of the upcoming Super Bowl, it is important to keep in mind certain rules of play regarding forfeiture of arguments in federal courts of appeals. The Tenth Circuit reiterated two such rules in recent opinions....more

Butler Weihmuller Katz Craig LLP

Seeing May Soon be Believing: The Possible Expansion of Summary Judgment in Florida with Respect to Dash Camera Footage

Many transportation companies use dash cameras for purposes of defending against actions for liability. However, recently in Lopez v. Wilsonart, LLC, 275 So. 3d 831 (Fla. 5th DCA 2019), eyewitness testimony and an expert...more

Carlton Fields

Quick Trial Checklist

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This chart provides a quick reference regarding motions and objections that may be made immediately prior to, during, and immediately after trial to preserve issues for appellate review. ...more

Burr & Forman

Finally, We’re Back to “Put Up, or Shut Up”

Burr & Forman on

My clients who have defended against meritless claims over the last few years know why this is important. The Tennessee Supreme Court has finally restored the traditional summary judgment standard making it easier for these...more

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