Micah EcholsCharlie FinlaysonDavid SnyderSean Claggett

Getting Appellate Counsel Involved

Case studies where cases went wrong at trial on legal issues

  • Inadequate pleading, including punitive damages
  • Inadequate orders in limine
  • Improper Batson challenges
  • Unrecorded bench conferences
  • Inadequate offers of proof
  • Settling of jury instructions
  • Settling of the jury verdict form
  • Failure to timely challenge the sufficiency of the defenses.

What does an appellate attorney do prior to trial and during trial?

  • Prior to trial.
  • Oppose motions to dismiss
  • Consult on motions to amend prior to trial.
  • Consult or draft summary judgment motions and oppositions.
  • Draft motions in limine on legal issues.
  • Consult on pretrial orders that are appealable or likely subject to a writ petition.
  • Prepare jury instructions.
  • Prepare the jury verdict form.
  • Prepare trial briefs on legal issues.

During Trial

  • Participate in bench conferences
  • Provide legal support for evidentiary rulings and objections.
  • Assist with offers of proof.
  • Prepare additional trial briefs.
  • Keep track of additional needed jury instructions
  • Settle jury instructions
  • Settle the verdict form.
  • Oppose the defense motions for directed verdict.

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