If you have an upcoming trial, try this: spend thirty minutes, and draft one single motion. Don’t know what to ask for, then think of it this way. What’s one decision you would like from the judge that would make the trial more fair for your client. That’s it. One motion.

You obviously could set aside a few hours and draft several motions. But start with one. Then set it down for a hearing and argue it. If you win your motion, your trial will be more fair. If you lose your motion, you’ll provide a lawyer like me something to argue on appeal. And you may work the case out favorably without a trial by creating a moment to speak with opposing counsel on the day your motion is heard.

In most of the transcripts I read, the trial lawyer did not file even one motion.