Advo Dec22 cvr ezine

Articles in this issue:

Requesting the statement of decision

A process that can preserve, if not enhance, your chances on appeal after a bench trial goes awry


Showing what you’re worth

Prevailing party attorney-fee motions — your investment in yourself


How to defeat (almost) every MSJ

A step-by-step guide to preparing your opposition to motion for summary judgment


Well pleaded

Tips for drafting effective and well-organized complaints that can help you avoid unnecessary issues


Overcoming common defenses to plaintiffs’ recovery of 998 costs

How to evaluate the likelihood that your 998 offer will withstand defendant’s challenges


Preventing the abuse of the Sudden Emergency Doctrine

It is critical to establish the unsafe choices that the defendant made both before and after the purported emergency arose


Being famous is not enough

The onslaught of anti-SLAPP litigation requires us to preemptively research the viability of a potential anti-SLAPP response by the opposing party


When a post-judgment appeal just won’t do

Appealable orders and statutory writs: Finding [[case]]immediate relief[[/case]]


Motions in limine: misused and abused

Best practices when filing and opposing motions in limine


Beating a claim of “fraudulent joinder”

Show any possibility of recovering against a California citizen and your case should likely be remanded back to state court


Appellate Report

Court refines the trivial defect doctrine, rejects strict tape measure approach to determine whether a sidewalk defect is trivial. Also, 998 offers and peremptory challenges



New State Bar trust-account rules – what you must know now

Also: SB 1155 and a new statutory structure for bad-faith actions


The unexamined life . . .

A segue from being an Orange County trial lawyer to the philosophy of Socrates


Farewell, but not goodbye

As a [[case]]past[[/case]] president, I look forward to being the most relaxed person in the room