Best Practices in New Jersey Motion Practice

In this program, the Honorable Michael R. Casale, J.S.C. (retired), currently "Of Counsel" at Greenbaum, Rowe, Smith & Davis (Roseland and Woodbridge, New Jersey offices), will help you navigate the New Jersey Court Rules as to motion practice. The New Jersey Court Rule Book, with Comments, is the "Bible" for the litigation attorney. Yet, in his 20+ years of experience as a trial judge in the busiest county in New Jersey (Essex County), and as a Judicial Law Clerk (many, many years ago), it never ceased to amaze Judge Casale that attorneys consistently ignore even the most basic rules of motion practice. Relatedly, this program will examine Judge Casale's "Top Ten Issues with Motion Papers," and summarize the requirements for the most common motions in Civil and Family law.

Learning Objectives:

1. Understand the top ten issues with motion papers. What angers judges and their law clerks? What makes them happy?
2. Identify checklists for common civil motions. Ensure that you don't miss a key requirement of your motion.
3. Discuss pre-judgment motions. What are the most common types of motions in civil cases? In family cases? When should they be filed?
4. Review motions "in limine"-trial motions. When should they be filed? When should they be saved for the actual trial?
5. Explore post-trial motions, particularly the requirements for post-judgment civil and family motions. For family law practitioners, it is common that the real litigation starts after the Judgment of Divorce.