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#7 Trial Agreement – Unobjected-To Trial Exhibits Deemed Admitted
Unobjected-To Trial Exhibits Deemed Admitted All unobjected-to trial exhibits listed on the exhibit lists the parties exchanged before trial are deemed admitted when mentioned by any party during...
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#6 Trial Agreement – Deadlines to Exchange Exhibit Objections
Deadlines to Exchange Exhibit Objections Deadlines for exchanging exhibit objections and a time to meet and confer on them. Stephen Susman,ssusman@susmangodfrey.com
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#5 Trial Agreement – Agreed Motion in Limine
Agreed Motion in Limine An agreed Motion in Limine, plus a briefing schedule for contested motions. Stephen Susman,ssusman@susmangodfrey.com
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#4 Trial Agreement – Deposition Counter-Designations
Deposition Counter-Designations Deposition counter-designations will be counted against the designator’s time. Counter-designations for optional completeness will be played during the “direct...
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#3 Trial Agreement – Deposition Designations
Deposition Designations Deposition designations will be deferred until 48 hours before a party intends to read or play a deposition. The opposition then has 24 hours to object and counter-designate,...
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#2 Trial Agreement – Length of Trial and Time
Length of Trial and Time Agreement on the length of the trial and that time will be split equally Stephen Susman,ssusman@susmangodfrey.com
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#1 Trial Agreement – Date for Exchanging Real Live Witness List
Date for Exchanging Real Live Witness List Real live witness lists will be exchanged on agreed date. Any witness who appears on a party’s live witness list whom the other side has not deposed, can be...
View ArticleTrial Agreements Made Easy
These agreements will make life easier for both sides and do not advantage one side over the other. Waiting until you are in the heat of battle to try to reach these agreements, one side or the other...
View Article#1 Trial Agreement – Dispense with final Pretrial Order requirement
The parties will ask the court to dispense with the requirement of a final Pretrial Order and instead exchange witness and exhibit lists, deposition designations, and proposed jury instructions as...
View ArticleJudges Vow Renewed Crackdown on Attorney Discovery Abuses
By Bruce Kaufman “Recent judicial threats of big-dollar monetary sanctions against attorneys who use boilerplate discovery responses may indicate a renewed effort to crack down on obstructionist...
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