All Things Reconsidered: Getting It Right the First Time

November 16, 2021

Litigation often offers multiple opportunities to inject an argument or an issue into a case. Pleadings, motions, and responses to motions allow parties to frame the issues. Unfortunately, there are times when an adverse ruling provides the spark that prompts a party to raise what might have been the winning argument, had it been raised earlier. Whether an argument raised for the first time on a motion for reconsideration is considered timely and — our focus here — preserved for appeal depends very much on case law, which may limit a party’s ability to raise new issues on a motion for reconsideration.

Waiving the Personal Jurisdiction Defense

November 5, 2021

Taking Advantage of Preliminary Substantive Jury Instructions and Preliminary Charge Conferences: Practical Considerations and Tips

September 17, 2021

Florida Supreme Court Adopts and Codifies Apex Doctrine

August 26, 2021

Preserving Violations of Orders Granting Motions in Limine: Object Contemporaneously or Forever Hold Your Peace

May 25, 2021

Major Changes Yet Some Things Stay the Same: A Follow Up on the Three “Musts” for a Competent Affidavit or Declaration in Light of Florida’s Newly Amended Summary Judgment Rule

May 21, 2021

Moving for Judgment as a Matter of Law: How Specific Must You Be?

April 15, 2021

Appealing Alternative Holdings: Don’t “Sit Down on the Track” After Clearing “Just the First Hurdle in the Race”

March 12, 2021

Another Consideration Involving Unpreserved Error

February 16, 2021