Wednesday, January 4, 2012
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.