Court of Appeals decision rewards indefinite pleadings in family court
Posted Wednesday, December 9th, 2009 by Gregory Forman
Filed under Litigation Strategy, Of Interest to Family Law Attorneys, South Carolina Appellate Decisions, South Carolina Specific
A few years ago I stopped adding the catchall phrase “and for such other relief as the court deems just and proper” to my family
Procedural differences between temporary motions and other motions in South Carolina Family Court
Posted Wednesday, November 11th, 2009 by Gregory Forman
Filed under Family Court Procedure, Litigation Strategy, Of Interest to Family Law Attorneys, South Carolina Specific
Another post for my mentees. And I defy anyone to show me a motion for temporary relief filed in the South Carolina Family Court that
How does one draft an affidavit?
Posted Thursday, November 5th, 2009 by Gregory Forman
Filed under Litigation Strategy, Not South Carolina Specific, Of Interest to Family Court Litigants, Of Interest to Family Law Attorneys
For my mentees–and everyone else I have ever completely frustrated while trying to edit their affidavit: Almost any court hearing that does not allow testimony
Posted Wednesday, October 28th, 2009 by Gregory Forman
Filed under Litigation Strategy, Not South Carolina Specific, Of Interest to Family Law Attorneys
I am not one of those lucky souls who can speak extemporaneously in perfectly coherent paragraphs. Thus, when conducting cross-examinations, I am not surprised when
Posted Wednesday, October 28th, 2009 by Gregory Forman
Filed under Child Custody, Litigation Strategy, Not South Carolina Specific, Of Interest to Family Court Litigants, Of Interest to Family Law Attorneys
A few months ago I blogged on the concept that a child’s minority only lasts for 216 months and that the number of months of
How to deal with the witness who, on cross-examination, loses the ability to answer questions
Posted Wednesday, October 28th, 2009 by Gregory Forman
Filed under Litigation Strategy, Not South Carolina Specific, Of Interest to Family Law Attorneys
One of the things I am enjoying about mentoring newly-licensed attorneys is the opportunity to share little tips on how to deal with common litigation
Emergency hearings versus expedited hearings
Posted Friday, October 23rd, 2009 by Gregory Forman
Filed under Litigation Strategy, Of Interest to Family Law Attorneys, South Carolina Specific
Unlike a number of my family law brethren, I seek few emergency hearings; unlike almost all of my family law brethren, I seek many expedited
South Carolina Supreme Court allows writ of certiorari to challenge discovery order
Posted Tuesday, September 22nd, 2009 by Gregory Forman
Filed under Jurisprudence, Litigation Strategy, Of Interest to Family Law Attorneys, South Carolina Appellate Decisions, South Carolina Specific
The September 21, 2009 Supreme Court opinion in Hollman v. Woolfson, 384 S.C. 571, 683 S.E.2d 495 (2009) approves an unusual use of a writ of certiorari:
Orange juice and toast: Creating maximum damage from partial answers in depositions
Posted Monday, September 21st, 2009 by Gregory Forman
Filed under Litigation Strategy, Not South Carolina Specific, Of Interest to Family Law Attorneys
If I am deposing a hostile witness or opposing party, I often start with an innocuous line of questioning I call “orange juice and toast.”
How family court law on payment of attorneys fees alters negotiation strategy
Posted Monday, September 21st, 2009 by Gregory Forman
Filed under Attorney's Fees, Litigation Strategy, Of Interest to Family Court Litigants, Of Interest to Family Law Attorneys, South Carolina Specific
In a typical negotiation each party’s initial offer is the least generous offer they might hope the other party will accept. The rationale behind such
