Rule 5 of the Tennessee Rules of Civil Procedure addresses the requirements for the filing and service of papers in civil litigation. Generally speaking, "every order required by its terms to be served; every pleading subsequent to the original complaint; every paper relating to discovery required to be served on…
It was almost two years ago that I wrote about Wright v. Wright, No. M2007-00378-COA-R3-CV (Tenn. Ct. App. Dec. 12, 2007). (Post 1) (Post 2) Wright 1 is an opinion authored by Judge Walter Kurtz that reversed a decision to award a plaintiff’s lawyer a one-third contingent fee in a…
Fred Fresard, author of the Litigation Cost Control blog, has written three great posts on the steps to effective phone and video-conference depositions. As Fred explains, "the suitability of a deponent for remote examination depends on the importance of the witness to the ultimate outcome of the case, and the…
Scheduling orders are wonderful tools that are often overlooked by far too many plaintiff’s lawyers. One of the most important deadlines to put in a scheduling order is a deadline by which the defendant must allege the fault of a person not a party to the action. …
If you don’t understand the title of this post, you will want to log into the seminar that goes by the same name that is sponsored by AAJ. This seminar, exclusively for plaintiff’s lawyers, will analyze the USSC decisions in these important cases and explain how they will impact…
One of the battles in the preparation of scheduling orders is the deadlines for disclosure of expert witnesses. The defense always wants the plaintiff to go first, and wants an additional 30 or 60 or even 90 days to disclose its experts. Sometimes, the defense wants to depose the plaintiff’s experts before…
On August 11, 2009 I directed you to an article written by Steven Robbins on writing better emails. Here is a great article written by Jim Calloway on managing your in-box. Jim writes the "Law Practice Tips Blog," a great place to learn about law practice management and technology. An excerpt: if…
I love to read Dan Hull’s blog, What About Clients? He gets it. Or, more precisely, he gets most of it. He doesn’t get contingent fees, which puzzles me. But the rest of it is firmly within his grasp. Dan’s post, Litigation: Lawyering, Real Life and a Little Zen is one is wish…
Those of us who typically work for contingent fees have an extra incentive to work smarter. Like many of you, I have done a lot of reading in the field of time managment and project management, looking for ways to improve my productivity through better organization. I found this article on…
LIke you, I get a lot of emails every day. All too often, I permit emails to control my work schedule – a big mistake. Here is a nice article that gives suggestions for managing the mass of emails that enter our lives every day. The writer, Stever Robbins, accurately points…