Legal Writing for the Plaintiffs’ Trial Bar

In almost every case the defense will test the plaintiff’s case with a motion for summary judgment or a motion for summary adjudication of issues. Defeating these motions is the key to a successful plaintiff’s practice.

Once the summary-judgment motion is defeated, the case is on track for trial. Few defendants are willing to spend the money necessary to bring a case to trial, and many are unwilling to face the risk of having their case decided by a jury. As a result, defeating the summary-judgment motion lays the groundwork for settling the case on favorable terms.

We pride ourselves on our ability to effectively oppose summary-judgment motions. As a result of our experience, we avoid procedural mistakes that weaken the opposition, and we know how to capitalize on every mistake made by the other side.

About our legal services for attorneys

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 help plaintiff’s attorneys with any appellate matter in either the state or the federal appellate courts.

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.


Jeffrey I. Ehrlich, the lawyers’ lawyer

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.

He has authored briefs as amicus curiae in the California Supreme Court and the California Courts of Appeal on behalf of the Consumer Attorneys of California, United Policyholders, CalPIRG, and other consumer organizations. He is a member of the Consumer Attorneys of California amicus committee.

CAALA LogoThe Consumer Attorneys Association of Los Angeles (“CAALA”), the third-largest trial-lawyer organization in the United States, has twice honored him as its Appellate Lawyer of the Year (in 2004 and 2008). He is the first two-time winner of the award.