Winning Summary Judgment: Strategies, Discovery, and Drafting (CA & Federal) (OnDemand Streaming and Recorded Packages)

What You Will Learn

Agenda

Thursday, November 5, 2026
1:00 p.m. – 4:45 p.m. Pacific Time

Judges commenting throughout: Hon. Kira Klatchko (Recently retired CA Superior Court Judge) and federal court judge TBA.

1:00 p.m. – 2:00 p.m.
Federal Court vs. State Court

• Standards
  • FRCP 56 and section 2-1005
  • Two theories for winning SJ: “Traditional” motions vs. Celotex motions
  • Two theories for opposing SJ: Disputes of fact vs. Differing inferences from undisputed facts (the “reasonable jury” standard)
• The Big Difference: Local Rule 56.1
• Practical Differences
  • Federal court
  • State court

2:00 p.m. – 2:10 p.m.
BREAK

2:10 p.m. – 3:00 p.m.
Discovery for Summary Judgment

• Creating Undisputed Facts
  • Requests to admit
  • Depositions
  • Interrogatories
  • Admissibility issues
• Creating Disputes of Fact
  • Responding to written discovery
  • Depositions
  • Affidavits
• Exercises – Identifying Disputed vs. Undisputed Facts

3:00 p.m. – 3:10 p.m.
BREAK

3:10 p.m. – 4:00 p.m.
Drafting the Motion and Statement of Undisputed Facts

• Choosing your Arguments
  • Purpose and goals of SJ
  • Organizing and analyzing discovery
  • Selectivity vs. “Kitchen sink” approach
• Drafting the Motion
  • Why this comes first
  • Avoiding the “paper trial”
• Drafting the Undisputed Facts
  • Examples of proper vs. improper undisputed facts
  • Using exhibits effectively

4:00 p.m. – 4:45 p.m.
Drafting the Response and Statement of Additional Facts

• Disputing Facts
  • Parsing the statement of undisputed facts
  • Checklist: (1) material, (2) supported in the record, (3) admissible, (4) actually undisputed
• Drafting the Response Brief
  • Framing using the SJ standard
  • Arguing inferences
• Drafting the Additional Facts

Testimonials

The following testimonials are from our last Winning Motions for Summary Judgment, with a slightly different agenda.

“Phenomenal course. I’ve been lucky to have opportunities to really tackle summary judgment motions very early on in my career. Even then, this program was helpful in providing me tips, especially when it comes to reply to an opposition to a summary judgment motion. A must attend for newer lawyers.” – Christopher Williams, Esq.

“Speakers were very knowledgeable and clearly explained the topic.  The handout is very helpful as well.” – Matthew Dobbs, Esq.

“As a younger lawyer, the preparation of a summary judgment motion can be an intimidating task. This course was very informative and provided helpful information as to developing a plan in the early stages of litigation, to build towards a successful summary judgment motion.” – Christopher Williams, Esq.

“I enjoyed the program and the time went quickly.” – Matthew Dobbs, Esq.

“Satisfied, there was good information provided by all.”

“It was very informative and the examples are very helpful.”

“Great information and insight from judges.”

“The speakers were very good about explaining why we should and should not do certain things with regard to preparing motions for summary judgment.”

Faculty

Additional Federal Court Judge TBA.

Hon. Kira L. Klatchko (Ret.)
Retired Judge, Certified Legal Specialist in Appellate Law
JAMS

Hon. Kira L. Klatchko (Ret.) is a retired California Superior Court judge and serves as a neutral with JAMS. She has conducted hundreds of mediations and settlement conferences in civil, probate, family and appellate matters, bringing extensive judicial and appellate experience and a practical, court-informed approach to dispute resolution.

Judge Klatchko served nine years on the Superior Court of California, Riverside County. For seven years, she presided over an unlimited civil department, managing thousands of cases from inception through resolution and developing deep experience in business, real estate, land use, construction, contract, employment, catastrophic personal injury, professional negligence, civil rights, insurance, trust, government and complex matters. She also sat for two years in an independent family law department, handling marital dissolution, custody and support, asset division, premarital and postmarital agreement, domestic partnership, adoption, move‑away and international custody, and domestic violence matters.

Judge Klatchko twice served as a justice pro tempore on the California Court of Appeal, Second District, where she reviewed appellate briefs and writ petitions and drafted opinions in civil, criminal, family, juvenile and complex matters.

Before taking the bench, Judge Klatchko was a certified civil appellate law specialist and appellate practice leader, founding and chairing an appellate practice group at a California firm and later serving as partner and vice chair of a national appellate practice. She handled and oversaw appellate matters in California and federal courts, including the Ninth Circuit, and U.S. Supreme Court, among others, and is co-editor of a leading California appellate treatise. She has written and taught extensively on civil procedure and appellate law, including as a senior research fellow at UC Berkely Law’s California Constitution Center.

Judge Klatchko is known for her preparation, procedural expertise, and thoughtful, efficient approach to dispute resolution.

Tracy Fehr is a founding partner of Alexander Morrison + Fehr LLP, a plaintiff‐side employment and civil rights firm located in Century City. Ms. Fehr primarily represents employees in appeals, negotiations, and litigation.

Ms. Fehr developed a passion for appellate work after handling and winning all three parts of a consolidated triple appeal over a decade ago, preserving a single mother’s six‐figure verdict and reversing a low attorney fee award for remand and recalculation.Thereafter, Ms. Fehr began handling her firm’s appeals and writs and expanded her practice to take on appeals for other firms and attorneys. Her most recent published decisions include: Bassett Unified School District v. Superior Court (Ross) (2023) 89Cal.App.5th 273, discussing judicial ethics and affirming the trial judge should not be disqualified, preserving a million retaliation verdict; and Doe v. Superior Court (NaHoku) (2023) 95 Cal.App.5th 346, a case of first impression in the First District regardingan employer’s waiver of its right to binding arbitration by failing to pay on time. Ms.Fehr frequently co‐counsels and consults on appellate and employment matters and enjoys mentoring newer attorneys.

Ms. Fehr is a member of the Executive Board of the California Employment Lawyers Association (CELA), Chair of its Amicus Committee, and editor‐in‐chief of its employment law Bulletin. She was also recently invited to join the Los Angeles County Bar Association’s State Appellate Judicial Evaluation Committee. Ms. Fehr has been named a Super Lawyer by Super Lawyers Magazine every year since 2017. In 2020 and 2024, the Daily Journal named her one of the Top Women Lawyers in California.

Jesse Lanier is a Deputy City Attorney wirh the San Francisco City Attorney’s Office Complex and Affirmative Litigation Team. Prior to joining the City Attorney’s office, Jesse was a partner with Conrad|Metlitzky|Kane where her practice focused on complex civil litigation including business torts, contracts, and intellectual property disputes.

Jesse has over a decade of experience in all aspects and stages of litigation, including trial. Her keen ability to present a cogent and compelling narrative, honed by her time as a journalist, makes her an effective advocate for her clients.

Before joining Conrad|Metlitzky|Kane, Jesse was a litigator at Durie Tangri (which was acquired by Morrison Foerster), and served as a law clerk to the Honorable Jeffrey S. White on the United States District Court for the Northern District of California. Prior to her clerkship, Jesse was an associate at Holland & Knight.

Jesse received her law degree, cum laude, from the Boston University School of Law, where she served as an Articles Editor for the Journal of Science & Technology Law and directed the law school’s sketch comedy show. She has a master’s degree in documentary filmmaking and a bachelor’s degree in journalism—both from New York University, where she was elected Phi Beta Kappa. She is currently a member of the Edward J. McFetridge American Inn of Court and serves on the Association of Business Trial Lawyers Leadership Development Committee. 

Panish | Shea | Ravipudi LLP

Andrew Owen focuses his practice on litigating and trying catastrophic personal injury and wrongful death cases involving trucks, commercial vehicles, pedestrians, industrial or construction accidents, as well as dangerous conditions of public and private property.  Mr. Owen also devotes a portion of his practice to consumer class actions against businesses that engage in unfair and illegal business practices.

Prior to joining Panish | Shea | Boyle | Ravipudi LLP, Mr. Owen worked as a paralegal, law clerk and attorney at O’Donnell & Associates, a boutique civil litigation and trial firm that specialized in complex, multi-million dollar state and federal lawsuits involving antitrust, entertainment, intellectual property, energy, securities, products liability, toxic tort, real estate, constitutional law, finance, and business disputes.

Some of Mr. Owen’s prior work included: In re Katrina Canal Breaches Consolidated Litigation:  twin suits against United States and a private contractor alleging their negligence caused plaintiffs’ flood damage during Hurricane Katrina. State of California ex rel. Hindin v. Hewlett Packard Company and Agilent Technologies Inc.: qui tam suit for violation of California False Claims Act. The State of Nevada v. Watanabe:  white-collar criminal defense of gambler involving a gaming debt of over million. In re Natural Gas Anti-trust Cases I, II, III, IV:  consumer class action antitrust case concerning natural gas price fixing during 2000-01 energy crisis.

Mr. Owen has been named among the Best Lawyers in America® in the area of Personal Injury Litigation – Plaintiffs, recognized as a Southern California Rising Star by the Super Lawyers publication, and is a member of the State Bar of California, the United States District Court for the Central District of California, the United States District Court for the Eastern District of Louisiana, and the Fifth Circuit Court of Appeals.  He is also an active member of the Consumer Attorneys Association of Los Angeles.

While working as a law clerk, Mr. Owen attended the night program at Southwestern Law School where he graduated cum laude.  He earned Highest Honors in Legal Research & Writing, Alternative Dispute Resolution, and California Pretrial Practice.  Mr. Owen was also an active member of Moot Court and competed in the 2008 National Telecommunications Competition at Catholic University, where his team won First Place and he won Best Oralist.

Matthew is Senior Counsel with Colantuono, Highsmith & Whatley’s litigation practice group and resident in our Pasadena office. Matthew litigates a range of disputes for our public agency clients in both trial and appellate courts, including suits involving inverse condemnation, utility user taxes, Public Records Act disputes, post-redevelopment disputes, rates and fees, government contracts, land use and cannabis regulation.

Before joining CHW, Matthew served as Chief Deputy Public Defender for Stanislaus County.  In this role, Matthew managed a team of attorneys defending misdemeanor cases, including violations of local ordinances, coordinated with city and county officials on nuisance abatement strategies, and helped formulate his agency’s response to the COVID-19 pandemic.

As a deputy public defender, Matthew conducted 25 jury trials to verdict in felony and misdemeanor cases. He has filed writs and appeals in local and appellate courts and has extensive motion-practice, including Pitchess motions and Cervantes hearings.

While in law school, Matthew worked as a legal assistant for the Department of the Treasury’s Office of Inspector General.  He also served as the Executive Senior Editor for the Georgetown Journal of International Law and on the board of the Equal Justice Foundation.

Matthew graduated magna cum laude from Georgetown University Law Center. At graduation, he received the Alan Goldstein Award for excellence in criminal defense and was inducted into the Order of the Coif. He received a Bachelor of Arts in Philosophy from the University of California, Irvine, where he was a Regents’ Scholar and graduated with Scholastic Merit.

Downey Brand LLP

Zachary Streiff excels at resolving complex business disputes both in and outside the courtroom. Whether through negotiation, mediation, or vigorous litigation, Zach is tireless in pursuing the best possible results for his clients.

Zach’s clients are diverse, ranging from technology companies and Silicon Valley startups to California public entities, retail and hospitality businesses, as well as legal, healthcare, and financial professionals. His broad litigation experience includes actions involving breach of contract, harm to business interests, real property, and family trust disputes, among others.

Prior to joining Downey Brand, Zach practiced law for five years at a small firm in Monterey County. Before that, he served as a research attorney for the Civil Department of the Monterey County Superior Court. After graduating from law school, Zach practiced for two years with the U.S. Department of Justice, Executive Office for Immigration Review, through the U.S. Attorney General’s Honors Program.

Additional Federal Court Judge TBA.

Fees

Pre-order now and save $25 on your purchase with the Early Bird Rate!* Early Bird Expires September 15th!
(discount will be applied automatically at check out)

Fees & Format Options

💻 OnDemand Streaming

Watch the recorded seminar on your own schedule, as often as you’d like, from any device. Access lasts one year from purchase.

• Standard Rate: $299
• Early Bird Rate: $274*
• Includes: Seminar recording + written materials
• For individual use only

Group rates available for 3–4 attorneys watching together. Licenses available for 5+ attorneys—contact us for details. info@pincusproed.com or (877) 858-3848.

📦 Recorded Packages (Download, DVD, or CD)

These packages are for a single viewer and include seminar materials.

▶️ Video Recording (Download or DVD)

• Standard Rate: $299
• Early Bird Rate: $274*
• For individual use only

🎧 Audio Only Recording (Download or CD)

Great for listening in your car or on the go.

• Standard Rate: $299
• Early Bird Rate: $274*
• For individual use only

🎥 + 🎧 Video + Audio Combo (Download, DVD, or CD)

• Standard Rate: $349
• Early Bird Rate: $324*
• For individual use only

Shipping & Tax: $12 shipping added to DVD/CD orders (plus sales tax in CA)

🗓️ Availability

This program will be recorded live on November 5th, 2026.
OnDemand Streaming and Recorded Packages will be available approximately 2–3 weeks after the seminar. If you need access sooner, direct Zoom links will be provided.

⚠️ Important Notes

• OnDemand Streaming can be viewed on any device.
• Recorded Downloads must be downloaded to a computer first before transferring to another device. Files are delivered as a zipped folder containing the recording and written materials.

💼 Group Access & Licensing

Discounted rates are available for 3–4 attorneys watching together (Live or OnDemand).
Licenses are also available for firms or agencies with 5+ attorneys.

To inquire or purchase group access:
📧 info@pincusproed.com | ☎ (877) 858-3848

CLE Credit

🎓 CLE Credit Information

California:
Approved for 3.25 General CLE credits.

New York:
This program is eligible for 3.25 General CLE credits under New York’s Approved Jurisdiction policy.
Pincus Professional Education is a California Accredited Provider, and California is an approved jurisdiction under Section 6 of the New York State CLE Board Regulations and Guidelines.

🌎 Other States

CLE credit is officially approved in the states listed above.
If you practice in a different state, we’re happy to help—upon request, we will provide the materials and information you need to apply for CLE credit on your own. Many of our past attendees have successfully obtained credit in other jurisdictions.

To request assistance:
📧 info@pincusproed.com | ☎ (877) 858-3848