I've been a little scarce on here for the past couple of weeks. Was preparing for multiple trials, and actually went to trial last week on a case. I'll discuss the trial in a later post.
For those lawyers who read this blog, I will tell you a few key items from the trial: Always prepare a Trial Notebook for the Judge. Include in it a Trial Brief. A short statement of the facts, the key statutes and cases, with a copy of all. It helped once again for me. An informal poll seems to suggest that less than 2/3's of lawyers I know prepare one. Big mistake.
Another: Submit only those Jury Instructions you absolutely need. The Court has its standard ones, of course. I submitted seven, and the Court agreed to read six of them. Opposing counsel submitted more than 40.