Mr. Kramer and his team surpassed all of my expectations.
| WHAT COURT? | COMPLAINT | SERVICE OF PROCESS | PRELIMINARY MOTIONS | ANSWER THE COMPLAINT | DISCOVERY | DUTY TO SUPPLEMENT | PRE-TRIAL MOTIONS | TRIAL | POST-TRIAL MOTIONS | APPEAL |
|---|---|---|---|---|---|---|---|---|---|---|
| ► Power to Hear Type of Case ► Power over Defendant [D] ► Venue: The right county/location. | ► Concise Factual Allegations Supporting Each Element of Claim ► Requesting Damages or Other Relief ► Liberal Amendment Policy Prior to 15 Days of Trial ► Need Leave to Amend Within 15 Days of Trial [amendment stricken if prejudice to opposing party] . | ► Process = [1] summons + [2] complaint ► Methods of Service: 1. Personally Serving D; 2. Certified Mail; 3. Serving Corp.'s Resident Agent/President / Secretary/Treasurer . | ► For More Definite Statement ► To Strike Certain Allegations ► To Dismiss * waivable defenses * non-waivable defenses | ► Specific v. General Denials ► Defenses: * Non-Waivable Defenses omitted from Preliminary Motion | ► Within Scope? * depositions | ► All discovery responses, except depositions ► Sanctions for Failure to Cooperate in Discovery? | ► Default Judgment ► Involuntary Dismissals for Lack of Prosecution ► Voluntary Dismissals ► Summary Judgment. | ► Voir Dire: Selecting the Jury ► Opening Statements ► Presentation of Evidence: * Plaintiff [P] v. Defendant [D] --> P's Case-in-Chief D's Motion for Judgment? --> D's Case-in-Chief P's Motion for Judgment? Either side must move for judgment at close of all evidence to preserve post-trial motion for JNOV! Jury Instructions Closing Arguments Verdict | ► 10-Day Motions:for Judgment Notwithstanding the Verdict [JNOV] * for New Trial * to Alter/Amend a Judgment ► 30-Day Revisory Power | ► Final Judgment? ► Timely Notice of Appeal? |
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