OTLA Trial Lawyer Winter 2024

Table of Contents	1
President’s Message: Council on Court Procedures and you	2
View from the Bench: A judicial perspective on motion practice	4
I've Got No Quit In Me: A cowboy approach to motions to compel	6
Privileges in Depositions	10
No Safe Harbor: Securing fee awards under fee-shifting	14
Annual Partners	17
Motions in Large Trials	18
On the Offense: Attacking frivolous affirmative defenses & requests for admission responses	22
The Beating Heart: You and your appellate lawyer	25
OTLA Guardians of Civil Justice	28
Battling the Preemptive Suit with a special motion to strike	30
Difficult Defense Counsel: Embracing a broader perspective	33
Stipulated Protective Orders: Making them work for you	36
Comp Corner: Motions in workers’ comp	41
Between the Sheets	42

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