Description
Step-by-Step Federal Trial Preparation
Preparing for Trial in Federal Court puts all the litigation building blocks at your fingertips, in one, easy-to-access volume. This comprehensive practice guide takes you from initial organization and case strategy, through pleading, discovery and motion practice, all the way through to final trial preparation and appeal issues. Loaded with proven practice tips and litigation-tested forms, Preparing for Trial in Federal Court will help you deftly and efficiently handle all the phases of federal litigation, including:
- Structuring the case
- Planning conferences and initial disclosures
- Written discovery
- Depositions
- Discovery problems
- Electronic discovery
- Experts
- Pretrial motions, including motions for summary judgment
- Settlement and ADR
- Witness preparation
- Marshalling evidence
- Ensuring admissibility of evidence
- Motions in limine
- Pretrial conference
- Voir dire
- Opening statement
- Direct, cross and expert witness examinations
- Trial motions
- Closing arguments
The free Digital Access that accompanies the book contains over 130 forms to help speed your drafting time. The forms include:
- Quick Reference Notebook
- Affirmative Defenses
- Stipulation to Allow Plaintiff to Amend Complaint
- Deposition Outline
- Motion to Strike Experts
- E-Discovery Preservation Letter
- Witness Briefing Checklist
- Deposition Outline Expert – Daubert Issues
- Trial Plan
- Defendant’s Motion in Limine to Exclude Test of Plaintiff Expert
- And many more!
REVISION 4 HIGHLIGHTS
The new edition of Preparing for Trial in Federal Court includes new and revised text in 5 chapters, plus 10 new forms. Author Nancy Pridgen explains the governing law and offers practice-oriented advice on numerous common, but complex, matters of federal litigation, including bankruptcy and class actions. The highlights include:
NEW TEXT
- Effect of Bankruptcy Filing On Pending Federal Litigation
- When Bankruptcy is Filed by Defendant
- When Bankruptcy is Filed by Plaintiff
- Pleading Requirements in a Class Action
- Considerations for Class Action Planning Conferences
- E-Discovery Considerations in Class Action Lawsuits
- Proposed 2015 FRCP Amendments: Anticipating Significant Rule Changes with Regard to E-Discovery
- Motions for Attorney’s Fees
- Motion for Class Certification
NEW FORMS
- Notice of Automatic Stay
- Proof of Claim
- Motion to Dismiss for Lack of Standing — Bankruptcy
- Plaintiff’s Motion for Attorney’s Fees
- Opposition to Motion for Attorney’s Fees
- Motion for Approval of Class Counsel’s Attorney’s Fees and Costs
- Opposition to Class Counsel’s Request for Attorney’s Fees and Costs
- Motion to Certify Proposed Class; Appoint Class Counsel; Approve Form and Manner of Notice to Class; and Approve Settlement
- Motion to Decertify Class
- Motion to be Appointed Interim (Lead) Class Counsel
Appendix 7-A List of Federal Statutes with Attorney’s Fee-Shifting Provisions
This comprehensive (50-page!) list covers nearly 400 statutes – from 2 U.S.C. §288i(d) to 50 U.S.C. §1828 – and includes the specific statutory language authorizing fee shifting. Rely on this list to help you work more efficiently. Drop the statutory language directly into your motion, and use it as a starting point for further research.
ABBREVIATED TABLE OF CONTENTS
Chapter 1 ORGANIZATION AND STRATEGY
Chapter 2 PLEADING PRACTICE
Chapter 3 PLANNING CONFERENCES AND INITIAL DISCLOSURES
Chapter 4 DISCOVERY
Chapter 5 ELECTRONIC DISCOVERY
Chapter 6 EXPERTS
Chapter 7 MOTIONS
Chapter 8 SETTLEMENT AND ADR
Chapter 9 PRETRIAL PREPARATION
Chapter 10 JURY ISSUES
Chapter 11 FINAL TRIAL PREPARATION
Chapter 12 APPEAL ISSUES
Table of Statutes
Table of Cases
Index
ABOUT THE AUTHOR
Nancy Pridgen is a partner and managing member of Monnolly Pridgen LLC (“MP Law”). Ms. Pridgen’s practice focuses on employment litigation in the federal courts, including her specialty in ERISA litigation. Ms. Pridgen has litigated literally scores of federal cases throughout the country. In addition to her employment litigation experience, Ms. Pridgen has litigated a wide array of cases, including complex commercial litigation, securities, insurance, tax, immigration, antitrust, constitutional and common-law torts, and civil appeals. In addition to her active trial practice, Ms. Pridgen has maintained her commitment to giving back to the community by, among other things, handling many low-cost or pro-bono adoptions, both for private individuals and through
Atlanta Legal Aid’s Grandparent/Relative Adoption Project.
Ms. Pridgen clerked for two federal district court judges, worked with Detroit’s U.S. Attorney’s office, Michigan’s Attorney General’s office, BigLaw, and a medium-sized law firm, and now owns and runs a successful boutique employment firm with her law partner in Atlanta, Georgia. Ms. Pridgen is a proud graduate of Auburn University, where she graduated first in her class, summa cum laude, as the President’s Award-winner for the College of Liberal Arts for her graduating class, with a double major and in the University Honors Program. She received her law degree from Vanderbilt Law School, where she served as a Managing Editor of the Vanderbilt Law Review, and was named NAWL’s Outstanding Woman Law Graduate for her class, in addition to her Dean’s List honors. Ms. Pridgen writes and speaks often on ERISA/employment litigation topics; you can access the titles of her publications and speaking engagements by visiting her website, www.mplaw-llc.com.
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