Jim Allen is our latest Featured Speaker

Jim Allen

Jim Allen is our latest Featured Speaker!

Jim is a retired Assistant County Attorney for Miami Dade County and has been sharing his experience with our attendees since 2014, when he first spoke at our Circuit Court Boot Camp in Ft. Lauderdale. Since then, Jim has been a frequent speakers at many of our litigation programs. Most recently, he spoke at Mastering the Deposition and Brief Writing in Ft. Lauderdale. Next year, Jim will join us again for our 5th Annual Circuit Court Boot Camp in Ft. Lauderdale.

In addition to providing excellent tips and litigation strategies, Jim always provides thorough handouts and additional materials that attendees rave about.

Jim Allen
Former Assistant County Attorney, Miami-Dade County

Jim was Chief of Training and Development, while continuing to maintain a full caseload in state personal injury and federal civil rights actions.

As a litigator, Jim has practiced extensively in federal and state court at both trial and appellate levels. He has litigated and tried numerous cases involving serious wrongful death and civil rights allegations, including a taking action claiming in excess of 100 million dollars in damages. Jim has also handled numerous state and federal appeals, including a case filed in the U.S. Supreme Court.

After law school, Jim clerked for the Honorable James R. Jorgenson, Florida Third District Court of Appeals.  Jim is a graduate of the University of Wisconsin, J.D., Cum Laude, 1980.

Summary Judgment Motions – Tips from the Trenches

Karen

Our speakers are always providing our attendees with helpful tips for their practice, and Karen Kimmey of Farella Braun + Martel is no exception!  When she speaks at our CLE programs, Karen provides great handouts. She provided one on Summary Judgment Motions not too long ago. Here are a few simple tips to improve your briefs:

MOTIONS FOR SUMMARY JUDGMENT 

Practice Tips

  • Think strategically about whether to file for summary judgment regardless of odds of winning. What are you goals?D Do you want to educate your judge? Are you trying to preview your opponent’s evidence? Always remember to consider the cost and effort involved in a Motion for Summary Judgment – it can get very expensive for your client.
  • Spend more time on your Separate Statement of Facts
    • Too often this is an afterthought for counsel – but the judges and their law clerks read these thoroughly. It is the document most relied-upon by many judges and clerks, so be careful with it, and make it easy for the court to find your references and cites.
  • Include only those facts in your Separate Statement that are truly “material”
    • The Court may assume it is material if it is in your Separate Statement
    • Each fact should be discrete and independent
  • Focus on your introduction and headings
    • Explain in a couple sentences what relief you are seeking and why you are entitled to it
    • Use argumentative headings to guide the argument
  • Do not bother with a long recitation of summary judgment standards – they know what it is. Save the space and word count for your argument.
  • Simplify if you are seeking summary judgment and complicate if you are opposing it
  • Start the process early – it takes a lot of time to prepare the papers