Every good trial lawyer knows it’s important to “preserve the record for appeal,” but doing so is easier said than done. In an article for the ABA’s Solo, Small Firm and General Practice Division, Waymaker of counsel Becky James offers strategic advice for lawyers seeking to make an adequate record without jeopardizing the success of their case at the trial court level. Her article discusses real-world preservation scenarios such as pleading defects, summary judgment, motions in limine, evidentiary objections, jury instructions, and post-trial motions.
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