Wednesday, January 4, 2012

Trial Judges Give Advice on Drafting Motions

Last November, four Houston trial judges joined in a roundtable discussion on motion practice. Here are just a few pieces of their advice:

1. Be very clear on what relief you want and why you are entitled to it.

2. Don’t forget to include a proposed order with the motion.

3. When there are numerous parties and entities involved or  the facts  are complicated, you can help the judge out by including a  flowchart and a time line.

4.  In the average case, a half page summary of facts is enough.

5. In motions in limine, skip the boilerplate.

Here is a link to the full discussion.


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