Limitations of Actions; statutes of limitation; statutes of repose; laches; determination of parties; misjoinder or non-joinder of parties; substitution of parties; standing; intervention; interpleader; alternate dispute resolution; mediation; arbitration; venue; complaints; filing and service of process; answers; preliminary motions; affirmative defenses; counterclaims; cross claims; third party complaints; amended and supplemental pleadings; declaratory relief; attachment and garnishment; preliminary or permanent injunctions; lis pendens; rescission; reformation; accounting; damages; limitations on recovery; Case Management and Pretrial Conferences.


Discovery strategy and planning; scope of discovery; relevant evidence; opposing discovery; trial preparation material; privileges; motions to compel; protective orders; preservation of evidence; discovery of electronic information; depositions; interrogatories; document production; requests for admission; expert witness information; protective orders; sanctions.      


Preliminary motions; limiting or defining discovery; resolving case prior to trial; limiting issues or obtaining dismissal at trial; challenges to jurisdiction; motions to strike; stipulations; consolidation; severance; default; summary judgment; voluntary dismissal; sanctions; compelling discovery. 


Judicial notice; presumptions and burden of proof; relevancy; judicial limitations; privileges; work product; witnesses; examination; sequestration; impeachment; rehabilitation; expert testimony; opinion; hearsay and exceptions; documentary evidence; real and demonstrative; best and secondary evidence; authentication; parole evidence.


Preparation; compelling attendance of witnesses; production of evidence; subpoenas; record preservation; evidentiary matters; prejudice; opening statement; witnesses exclusion; limitations on testimony; direct examination; cross-examination; expert witnesses; documentary evidence; document admissibility; trial motions. summation; post-trial motions; costs, fees and interest; orders and judgments.


Beneficiaries Rights. Determination of beneficiaries and heirs; intestate succession; inheritance rights; appointment of personal representative; discovery of later will; right to possession of property.

Will Contests. Grounds for contest; execution or qualification; incompetency; fraud, duress or undue influence; revocation of will; standing to contest; renunciation of benefits; pleadings; petition for revocation of probate; replies to petition; related motions, discovery; trial; testimony; documentary evidence; mediation and settlement; fee recovery.

Family Rights. Elective share of surviving spouse; exempt property; family allowance; prenuptial and postnuptial agreements; pretermitted spouse and children.

Asset Titling and Ownership. Tenancy in common; joint tenancy; tenancy by the entireties; creation of joint interests by gift; burden of proving gift and presumptions; retitling of accounts prior to death of party; beneficiary designation bank accounts; transfer-on-death security registration.

Creditor Claims. Three month claim filing requirement; two year non-claim statute; objections to claims; actions to enforce claims; payment and apportionment of claims; tolling of limitations.

Will Construction. Jurisdiction and choice of forum; petitions and responses; rules of construction; admissibility of extrinsic evidence.

Homestead Litigation. Constitutional and statutory provisions; forms of ownership; possession of homestead by personal representative or trustee; life estates and remainder interests; alienation during life; restrictions on devise of property; exemption from creditors; waivers of protection. 

Removal of Personal Representative or Trustee. Statutory grounds; conflict and hostility; endangerment of estate; removal proceedings; standing, jurisdiction and venue; accounting, assets distribution and administration records; administration following removal; surcharge and liability of personal representative and trustee for breach.

Trust Litigation. Grounds for trust contests; execution or qualification; fraud, duress or undue influence; commencement; parties; standing; virtual representation; jurisdiction in trust actions; trust actions involving probate administration; principal place of administration and venue; evidentiary issues; privileges, work product and extrinsic evidence.





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Our Office

  • Sarasota Office


    2201 Ringling Boulevard,
    Suite 104,
    Sarasota, Florida 34237