Matthew J. Conigliaro
Carlton Fields
Articles
Proffers 101: when to make your offer of proof
USA - May 4 2015 Where a party challenges a trial court’s ruling excluding testimony, appellate courts generally require the substance of the excluded evidence to…
Pre-trial problems: summary judgment & evidentiary rulings
USA - December 8 2014 The Fifth Circuit's decision in Blessey v. Marine Services, Inc., --- F.3d ---, 2014 WL 5837059 (5th Cir. Nov. 10, 2014), highlights two different…
4 ways not to preserve objections to jury instructions
USA - October 8 2015 The trouble began with an off-the-record charge conference. Both sides proposed standard breach of contract jury instructions, but the defendant…
New twists on Florida’s ‘tipsy coachman’ doctrine
USA - August 27 2013 A recent Florida appellate decision examines some new twists on Florida's "tipsy coachman" doctrine. Before we discuss the new decision, though, it…
Avoiding Trouble Following In Limine Rulings
USA - March 1 2016 Trials often are preceded or interrupted by hearings on motions in limine, where parties attempt to limit the evidence or arguments that their…
