New York Trial Notebook - Volume 1

Preliminary Sections

• Preliminary Sections
• About the authors

Case management

• New York Courts and New York Law
• Differentiated Case Management and Conferences
• Note of Issue, Trial Calendar, and Trial Preferences
• Jury Demand and Waiver
• Expert Witness and Medical Report Disclosure
• Post-Note of Issue Discovery

Motions before trial

• Amending and Supplementing Pleadings and Bills of Particulars
• Motions to Sever and Bifurcate
• Motion to Continue (Adjourn)
• Voluntary Discontinuance and Settlement
• Disqualification of a Trial Judge
• Disqualification of Counsel
• Motions in Limine and Motions to Exclude Persons From Trial

Preparing for trial

• Case Theme and Trial Notebook
• Qualification of Experts and Admissibility of Expert Testimony
• Preparing Witnesses, Exhibits and Final Filings
• Subpoenas: Compelling Witness Attendance and Productions at Trial
• Alternatives to Testimonial and Physical Proof

Trial

• Interaction With Trial Participants
• Jury Selection
• Opening Statement and Court's Preliminary Remarks
• Proof: Order, Burdens and Standards
• Eliciting and Refuting Testimony
• Direct Examination of Lay Witnesses
• Cross-Examination of Lay Witnesses
• Direct Examination of Expert Witnesses
• Cross-Examination of Expert Witnesses
• Presenting Nontestimonial Evidence
• Evidentiary Objections and Evidence Rulings
• Preparation and Presentation of Closing Argument
• Objections During Closing Argument
• Jury Instructions
• Verdicts and Verdict Sheets
• Jury Deliberations and Rendition of Verdict

Trial motions and post-verdict proceedings

• Motion for Judgment During Trial (Directed Verdict)
• Motion for New Trial During Trial (Mistrial)
• Other Motions During Trial
• Post-Verdict Proceedings
• Index