Charlie Finlayson

Micah Echols · Charlie Finlayson · David Snyder · Sean Claggett

Case studies where cases went wrong at trial on legal issues

• Inadequate pleading, including punitive damages
• Inadequate orders in limine
• Improper Batson challenges
• Unrecorded bench conferences
• Inadequate offers of proof
• Settling of jury instructions
• Settling of the jury verdict form
• Failure to timely challenge the sufficiency of the defenses.

What does an appellate attorney do prior to trial and during trial?

• Prior to trial.
• Oppose motions to dismiss
• Consult on motions to amend prior to trial.
• Consult or draft summary judgment motions and oppositions.
• Draft motions in limine on legal issues.
• Consult on pretrial orders that are appealable or likely subject to a writ petition.
• Prepare jury instructions.
• Prepare the jury verdict form.
• Prepare trial briefs on legal issues.

During Trial

• Participate in bench conferences
• Provide legal support for evidentiary rulings and objections.
• Assist with offers of proof.
• Prepare additional trial briefs.
• Keep track of additional needed jury instructions
• Settle jury instructions
• Settle the verdict form.
• Oppose the defense motions for directed verdict.