Entries by Donna Cole

Determining a Business Owner’s Income for Child Support

Accurate income figures are essential to child support calculations, but obtaining and agreeing on true income, especially when a parent is a business owner, can be a challenging process. Significant adjustments to reported income and expenses may have to be made to reflect the true economic benefit the parent derives from the business. Nicholas Bourdeau’s […]

General Damages — 16 Building Blocks to Higher Settlement Offers

Don’t let the adjuster simply double your client’s specials to determine pain and suffering. In How Insurance Companies Settle Cases, insurance expert Dave Frangiamore reveals these 16 building blocks, many overlooked by plaintiff’s attorneys, that carry weight with adjusters. When discussing general damages with the adjuster, you don’t want the adjuster to think that you […]

Federal Discovery — 10 Tips for Propounding and Answering Requests for Admission

Requests for admission (RFAs) are an extremely valuable, but significantly underused, discovery and litigation tool. They are an effective tool to help you streamline your case or defense. William Audet and Kimberly Fanady offer you these tips from their book, Handing Federal Discovery, for propounding and responding to RFAs. Propounding RFAs Combine interrogatories, requests to […]

Expert Depositions — 5 Tips to Improve Your Effectiveness

Deposing an expert witness can be intimidating.  With Evan Schaeffer’s Deposition Checklists and Strategies, you’ll be prepared to face the opposing expert (and other witnesses) with confidence. Here, excerpted from the book, are five tips to help you with your next expert deposition. Investigate the CV Before the Deposition. Don’t save your review of an […]

Plaintiff’s Lawyers — 7 Tips for Successful Mediation

In most substantial cases, mediation is the only road to settlement. Highly successful trial attorneys, Roger and Larry Booth, offer you these tips for getting a healthy settlement offer through mediation. You’ll find a wealth of additional advice for maximizing the value of your personal injury cases in their book, Personal Injury Handbook. Choose the […]

Injury Cases — Cross-Examining the Defense Doctor

Cross-examination of the defense doctor who examined your client should be an ambush. Get in quickly, get out quickly, sit down, and shut up. Kim Hart shows you how in this excerpt from his book, Deposing and Examining Doctors. Prepare for cross-examinations by creating a one-page outline that can be scanned quickly to determine if […]

5 Tips for Drafting Prenuptial Agreements

Most prenuptial agreement litigation is driven by these three factors: The seemingly ubiquitous lack of independent representation for both parties; a claimed or actual lack of full and complete disclosure of assets; and the “threat” of calling off the impending nuptials if the agreement is not signed. To prepare an agreement that will withstand these inevitable challenges, you […]