(305) 372-5220
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Attorneys
Roy D. Wasson
Annabel C. Majewski
Practice Areas
Business & Contract Litigation
Civil Rights, Defamation, and Personal Injury
Class Actions
Criminal Law
ERISA
Insurance
International Trade
Maritime
Product Liability
Administrative Law
Roy’s Trial Law Tips
Contact Us
(305) 372-5220
Home
Attorneys
Roy D. Wasson
Annabel C. Majewski
Practice Areas
Business & Contract Litigation
Civil Rights, Defamation, and Personal Injury
Class Actions
Criminal Law
ERISA
Insurance
International Trade
Maritime
Product Liability
Administrative Law
Roy’s Trial Law Tips
Contact Us
Roy’s Trial Law Tips
1
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Reply to Affirmative Defenses
2
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Don't Tell the Judge What Happened Outside the Courtroom
3
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Do Not Give Your Jury Instructions to the Judge
4
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Taking the Wind Out of Their Sails
5
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Making and Preserving Jury Challenges for Cause
6
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The Problem With Late Listed Witnesses-Prejudice is the Key
7
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Dismissal of Your Complaint Without Any Motion - Welcome to the Twilight Zone
8
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Mid-Testimony Conference with Clients About Their Testimony During Recesses in the Trial or Deposition
9
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Substantive Changes to Deposition Testimony
11
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Proving Damages for Loss of Consortium Claims
12
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Sayonara to Fundamental Error
13
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Amendments to Pleadings to Defeat Summary Judgment - Never Too Late
14
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Motions to Strike or for Partial Summary Judgment - A Rose is not a Rose
15
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Bifurcation of Trial Issues of Liability and Damages - To B or Not to B
16
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High-Low Agreements - Nothing Smellie About Them
17
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Your Star Witness Develops Sudden Amnesia
18
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Recovery of Court-Awarded Fees - Some Basics
19
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Motions to Amend to Conform to Evidence - Risky Business
20
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Acceptance of Workers' Compensation Benefits by Tort Claimant - An Election of Remedies
21
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The Meat of Establishing Jurisdiction Under Venetian Salami
22
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Enforcement of Settlements
23
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Introducing the Full-Amount of Written-Off Medical Bills
24
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Calling Witnesses to Summarize Records-Comply with Section 90-956 First
25
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Release and Dismissal of Active Tortfeasors - Simple Steps to Preserve Claims
26
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Preservation of Error - Inconsistent Verdicts
27
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Affidavits and Verifications - Notarization Not Always Necessary (or Sufficient)
28
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Proposals for Settlement in Sovereign Immunity Cases
29
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Requests for Admissions - Maximizing the Benefits
30
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Avoiding Summary Judgment with Affidavits that Conflict with Prior Deposition Testimony
31
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Pleading Claims for Punitive Damages
32
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Court Reporters Must Keep Typing Videotaped Testimony During Trial--No Rest for the Weary
33
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Motions to Disqualify Judges for Bias or Prejudice
34
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Civil Procedure 101 Revisited - Critical Difference Between Service and Filing of Documents
35
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Moving for Mistrial or Rolling the Dice - Having Your Cake and Eating it Too
36
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Proving Medical Standards of Care
37
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Plaintiff Dies Before Trial - Now What
38
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Dealing with 120 Day Deadline for Service of Process - Some Things Are Getting Easier
39
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Keeping Defense Doctors So-Called IME Reports Out of Evidence
40
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Recovery of Psychic Damages Without Waiver of Psychologist-Patient Privilege - Walking the Tightrope
41
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Refreshing Witnesses' Recollection with Inadmissible Documents
42
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Stalking Another Courthouse Legend - Award of Payment to Attorneys' Fees Expert Not Guaranteed
43
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Exclusion of Wrongful Death Survivors from Courtroom Under The Rule
44
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Reflections of a Trial Lawyer - The Image Is Not Always Clear
45
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Don't Let Jurors Conceal Prejudicial Litigation Experience
46
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Move All Exhibits Into Evidence Before You Rest - And What to Do If You Forget
47
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Keeping Non-Parties Off the Verdict Form Under Fabre
48
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Striking a Defendant's Pleadings for Tampering with Evidence May Jeapordize Insurance Coverage - Baby or Bathwater
49
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Discovery of Work Product Communications from Counsel to Experts
50
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Pleading Res Ipsa Loquitur as a Separate Count
51
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Recovering Loss of Earnings Capacity in US Dollars for a Plaintiff Who is an Illegal Alien
52
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Motion for Costs and Attorneys' Fees - Timeliness is All-Important
53
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Disclosure of Liability Insurance Information - Remedies for Insurer's Violation
54
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Payments to Witnesses - Lay and Experts
55
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Florida Legislature and Supreme Court Team Up - Records Custodians No Longer Necessary at Trial
56
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Overcoming Vague Objections that Discovery is Overly Burdensome'
57
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Overcoming the 'Sudden Stop' Defense in Rear-End Collision Cases
58
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Successor Judges Can Overturn Prior Non-Final Rulings of Original Judge
59
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Delaying Summary Judgment Hearings Due to Incomplete State of Discovery or Inability to Timely Get Refuting Affidavits
60
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Proffers of Evidence Supporting Amendments to Plead Punitive Damages
61
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Introducing Documents into Evidence
62
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Don't Voluntarily Dismiss a Defendant-File a Notice of Dropping Party Instead
63
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Remedies for Ex Parte Communications with Treating Physicians
64
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Dealing with Experts Who Turn Negative After Being Listed as Testifying Witnesses
65
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Florida State Courts Need Not Follow Holdings In Federal Courts-Even on Matters of Federal Law
66
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Removal to Federal Court-Post Removal Joinder of Non-Diverse Defendant Requires Remand
67
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Dealing with Judges Who Refuse to Set Actions for Trial
68
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Use of Discovery Materials on Summary Judgment Motions
69
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Offers of Judgment-Proposals for Settlement
70
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Inadmissibility of Evidence of Settlement with Former Defendants
71
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Use of an Expert Deposition Without a Qualifying Expert
72
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Requirement of Expert Testimony to Recover Expert Fees as Taxable Costs
73
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Graves Amendment Car Rental Issue Outline for Fallback Arguments
74
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Use of Non-Party Depositions at Trial
75
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Overcoming 'Sudden Loss of Consciousness' Defense
76
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Avoiding Statutes of Limitation When Identifying Incorrect Defendant in Complaint
77
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Providing Notice of Constitutional Challenges to Statutes
78
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Introducing Scholarly Publications - The 'Learned Treatise' Doctrine
79
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Experts Not Limited to Deposition Testimony
80
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Striking Defendant's Pleadings as a Sanction for Obscuring Evidence and Discovery Misconduct
81
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Overcoming Work Product Objections to Discovery of Incident Reports
82
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Motions for Reconsideration vs Motions for Rehearing - The Difference is Much More than Semantics
83
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No Need to Prove Permanent Injury in Uninsured Motorist Cases Involving Phantom Vehicle
84
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Planning for Federal Income Tax Consequences of Personal Injury Settlements
85
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Avoiding Having Experts Stricken in Federal Court
86
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Shortening the Time for Defense to Respond to Discovery or Other Filings Requiring Responses
87
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Reformation of Releases to Pursue Claims Against Additional Tortfeasors
88
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Avoiding Malpractice by Pleading Actual and Apparent Agency
90
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HIPAA No Match for Subpoena - Debunking a Courthouse Legend
91
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Successor Attorneys Need Not Split Fees with Wrongfully Discharged Prior Counsel - Another Courthouse Legend Bites the Dust
92
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Pleadings are Meaningless When Trumped by Pretrial Stipulation
93
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Affidavits are Not Admissible in Evidence
94
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Expert Depositions Inadmissible in Federal Court
95
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Your Client Dies Before Trial
96
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Attorneys Fee Sanctions-1
97
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Your Client Dies Before Trial-1
98
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Attorneys Fee Sanctions
