Your opponent files a motion for summary judgment. At a hearing on the motion, you point to an affidavit in the record to show that material questions of fact exist. Long before your opponent moved for summary judgment, you...more
Imagine a trial judge is trying to move things along at a charge conference. An issue arises, trial counsel begins to voice objections, and the judge short-circuits the discussion by saying, “Your rights are saved on the...more
The trouble began with an off-the-record charge conference. Both sides proposed standard breach of contract jury instructions, but the defendant added additional language. The trial court gave the defendant’s version. The...more