Four (4) pitfalls to avoid in your practice. #litigation #lawyer #californialaw #bestpractices 

Discovery on a practical perspective and/or per the California Code of Civil Procedure:
1) Case management/budget;
2) Initial disclosures;
3) responding to discovery including serving only objections;
4) propounding discovery.

#discovery #lawyerlife #lawyercoach #californiadiscovery

From my ghostwriting experience, I share several pointers in how to address motions for summary judgment.

Vallejo v. Montebello Sewer Co. (1962) 209 Cal.App.2d 721 at 730, 733:

Because the procedure is summary and presented on affidavits without the benefit of cross-examination, a trial by jury and opportunity to observe the demeanor of witnesses in giving their testimony, the affidavits filed on behalf of the [plaintiff] should be liberally construed to the end that he will not be summarily deprived of the full hearing available at a trial of the action and the rights incident thereto.