Trial / Post-Trial Writing Support for Trial Lawyers

Legal Writing for the Plaintiffs’ Trial Bar

Written advocacy in the trial court

While we enjoy appellate work and welcome any chance to handle an appeal, all too often we see that if we had been brought into a matter while the case was still pending in the trial court – particularly to oppose a summary-judgment motion – we could have avoided the need for an appeal and set the case in motion to settle. People need lawyers because the law is complex. Busy plaintiffs’ lawyers need our help for this same reason.

We can help you sort out the legal obstacles you must overcome in order to win your case, and prepare a powerful opposition to the following motions:

  • Motions under Daubert and Kuhmo Tires to exclude expert testimony;
  • Motions in limine;
  • Post-trial motions, such as motions for new trial, or JNOV;
  • Motions to compel arbitration; and
  • Where an insurer has refused to defend its policyholder in litigation brought by a third party;
  • Motions to quash for lack of personal jurisdiction

We can also prepare affirmative motions that can increase your chances to prevail, such as motions for summary-adjudication of issues; motions in limine, or motions to remand cases removed from state court to federal court.

We can defend favorable verdicts and attack unfavorable ones. We can draft writ petitions to seek appellate review of a devastating – but unappealable – trial court ruling, or respond to petitions filed by an opponent. We are experienced in seeking reversals in cases where the defendant has prevailed on summary judgment.

A lawyer’s lawyer

Our principal attorney is Jeffrey I. Ehrlich, a certified appellate specialist by the State Bar of California’s Committee on Legal Specialization. Few attorneys can match Mr. Ehrlich’s appellate experience.  His skill is in analyzing complex legal and factual issues, and presenting them to the court in a clear, persuasive manner. We can help plaintiff’s attorneys with any appellate matter in either the state or the federal appellate courts.

While much of Mr. Ehrlich’s experience has been focused on written advocacy, he also has significant trial experience, having tried several jury and bench trials in state and federal court, and having assisted Michael Bidart and Ricardo Echeverria of Shernoff Bidart Echeverria, LLP in winning multi-million-dollar verdicts for their clients.

Mr. Ehrlich is one of the few lawyers who has ever tried and won a claim for bad-faith denial of the existence of a contract – a tort that was created by the California Supreme Court in 1984 and abolished by that court 11 years later. Mr. Ehrlich’s case, Todt v. HOH Water Technologies, Inc., was tried in the U.S. District Court in Los Angeles, and resulted in a $765,000 judgment for the plaintiff, including an award of punitive damages.

Our Legal Services

Southern California appeals attorney, Jeffrey I. Ehrlich, is an appellate specialist certified by the State Bar of California’s Committee on Legal Specialization. He is the principal of the Ehrlich Law Firm, with Los Angeles County law offices.