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PRETRIAL. Limitations of Actions. Statutes of limitation. Statutes of repose. Laches. Parties. Determination of parties. Misjoinder or non-joinder of parties. Substitution of parties. Standing. Intervention. Interpleader. Forum. Alternate dispute resolution. Mediating disputes. Arbitration. Venue. Complaints. Drafting pleadings. Filing. Service. Answers.  Timing. Preliminary Motions. Affirmative defenses . Counterclaims and Cross Claims. Permissive or compulsory. Cross claims against co-defendant. Third Party Complaints. Intervention. Amended and Supplemental Pleadings. Service. Time for service. Extending or shortening time. Defects in service. Alternate Dispute Resolution. Mediating claims. Arbitration. Declaratory ReliefAttachment and Garnishment. Injunctions. Permanent injunctions. Temporary or preliminary injunctions. Lis Pendens. Recission. ReformationAccountingDamages in Tort. Pleading, proving and elements. Limitations on recovery. Damages in Contract. Compensatory, liquidated and lost profits. Case Management and Pretrial Conferences.

DISCOVERY. Discovery Strategy and Planning. Scope of Discovery. Discovery of relevant evidence. Opposing discovery. Trial preparation material. Privileges. Law and Motions.  Motions to compel. Protective orders. Preservation of Evidence. Before commencement of action. During action. Pending appeal. Discovery of Electronic InformationDepositionsInterrogatoriesDocument ProductionRequests for AdmissionExpert Witness InformationProtective Orders. Sanctions.

MOTION PRACTICE.  Preliminary Motions. Motions in pleadings. Limit or define discovery. Motions to resolve case prior to trial. Motions to limit issues or obtain dismissal at trial. Challenges to Jurisdiction. Subject matter jurisdiction. Personal jurisdiction. Motions to Strike. Striking witnesses and evidence. Striking pleadings. Removal. Stipulations. Drafting, using and enforcing. Consolidation, Severance and Separate Trials. Default. Obtaining, avoiding and vacating. Summary Judgment. Drafting, filing and serving. Affidavits. Responding. Hearings. Voluntary Dismissals. Involuntary Delay. Settlement. Offers, entering into and post-settlement. Sanctions. Compelling discovery. Sanctions for not providing discovery. Opposing motions.

EVIDENCE. Judicial Notice, Presumptions and Burden of Proof. Compulsory judicial notice. Discretionary judicial notice. Presumptions. Burden of proof. Relevancy. Limitations on admissibility of relevant evidence. Judicial limitations. Privileges. Attorney-client privilege. Work product privilege. Husband-wife. Accountant-client Trade secrets. Witnesses. Competency to testify. Examination of witnesses. Sequestration of witnesses. Refreshing recollection. Impeachment. Methods of impeachment. Rehabilitation of witnesses. Opinion and Expert Testimony. Expert witness testimony. Non-expert opinion testimony. Hearsay. Definition and components. Hearsay Exceptions. Admissions. Statements. Recorded recollections. Records of business activity. Public records and reports. Documents and statements affecting interests in property. Former testimony. Statements against interest. Real and Demonstrative Evidence. Photographs. Writings. Best Evidence. Secondary and other evidence. Authentication. Parole evidence.

TRIAL. Trial Preparation. Compelling Attendance of Witnesses and Production of Evidence. Subpoenas. Preserving the Record. Evidentiary matters. Prejudicial matters. Opening Statements. Exclusion of Witnesses and Limitations on Testimony. Direct Examination. Cross-Examination. Expert Witnesses. Documentary Evidence. Pretrial acquisition and preparation. Admissibility of documents and use at trial. Demonstrative Evidence. Trial Motions. Summation. Post-Trial MotionsCosts, Fees and Interest. Orders and Judgments.