Per accomplished litigator Hegel Laurent, who has had good success in this area, a lawyer should never file a §57.105 motion (also known as a Motion For Sanctions) unless the lawyer is ready to appeal the motion’s denial, which it will be … Continue reading →

Litigation in the Zoom World Prepare your client. Issues arise in virtual hearings that don’t exist where the matter is in person. A dry run is often appropriate, especially with unsophisticated clients. Centering, lighting, audio tests are all elements to … Continue reading →

Here I repeat one of my very favorite Tips. I present it annually as the first post-Labor Day Tip. I only wish I had been there! Thank you, Judge Altonaga for sharing. Expert Witnesses 9/8/2021 Do a thorough background check! … Continue reading →

Thoughts from Robert Galamaga, experienced Miami-based litigator: Bill, Always enjoy reading your tidbits. In follow up to the uncivility and hard ball tactics in depos, when one of “those” attorneys are opposing counsel, I will notice or cross-notice the deposition … Continue reading →

Last week’s Tip about applying for sanctions gave rise to some excellent comments.  Please excuse this relatively long Tip, but an email I received from Grace Casas, experienced Miami-based litigator is well worth sharing: I usually enjoy these tips but I did not … Continue reading →

Make sure you keep a proper pace when you are talking. Slow down, speak clearly. Don’t just look at yourself. You are in a courtroom setting. Your effectiveness as an advocate will be a function of how well you master … Continue reading →

Per Judge Alexander Bokor of the 3rd District Court of Appeal in a recent judicial panel: This is the moment for everyone to let go of their preconceived notions. This is the moment to consider: What does a trial mean? … Continue reading →

In this last Wednesday before 2021, please let me take this opportunity to wish everyone a Happy and Healthy 2021.  May it be a year first of good health, then peace, prosperity and good times for you and your loved … Continue reading →

Make sure you are familiar with and carefully follow the judge’s or magistrate’s instructions on the procedure and timing of filing of exhibits. Happy Thanksgiving.  I think it is safe to say that no one alive today has experienced a … Continue reading →

Per General Magistrate Robert Singer:  Many attorneys who appear before him don’t have an adequate knowledge of the evidence code.  Family law attorneys are susceptible and sometimes thrown off by more knowledgeable trial attorneys when they attempt to have a document … Continue reading →