It is often said that the best place to win an appeal is in the trial court. Sometimes, the appropriate motion or objection in the trial court will avoid the need for an appeal-p
erhaps the judge will rule in your favor, or perhaps opposing counsel will offer to settle the case on favorable terms. Even if you are likely to lose a motion, if it raises an issue that you plan to address on appeal, you must present that issue to the trial court in order to fully preserve it for the appellate court.
Since entering private practice, I have drafted close to 1,000 civil and criminal pretrial motions and supporting memoranda, including motions to suppress and dismiss on the criminal side and motions for summary judgment and in limine on the civil side.
Click to view a sample criminal memorandum or sample civil memorandum.