FasTrain Florida Civil Trial Preparation is designed to guide the attorney through all phases of trial preparation, from interviewing the client to preparing the closing argument and jury instructions. Details regarding trial notebooks, pretrial motions, discovery, and evidentiary issues are provided to help the attorney focus and advance the case, and settlement options are explored as a prudent alternative to trial. Each phase of preparation is individually covered, and thoroughly cross-referenced. Ervin Gonzalez, an outstanding, nationally recognized trial attorney, generously shares his valuable practice strategies and guidance in this thorough, easily digestible manual. Highlights of this edition include recent rule amendments addressing: • case management conference requirements; • electronic filing of pleadings; • electronic service of pleadings and documents; and • computation of time. Additionally, new articles and case law are discussed addressing issues such as: • disqualification of judges; • discovery of electronically stored information and privileged information; • remedies for failure to comply with discovery orders; • motions for summary judgment and responses thereto; and • exceptions to the right of voluntary dismissal.
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