Matthew J. Conigliaro

Carlton Fields

Articles

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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…

Sylvia H. Walbolt.

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…