1st trial (1st yr lawyer) and no one’s overseeing me. What is the average number of Motions in Limine to file? (Defending employer-entity and the part-owner/alleged harasser on hostile work environment-sexual harassment case)

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I'm not sure there is an average? I've had trials with 0 and trials with a bunch. It just depends.

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Yeah you have to determine the evidentiary issues in your particular case and move accordingly. Don’t file just to file like some lawyers. If there’s something you want in or out and you don’t want/feel you shouldn’t do it while the jury is present, file a motion.

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I agree there’s no average, but your local jurisdiction or the judge may have specific rules that limit MILs, so I’d check on that too.

There will likely be standard omnibus MILs for those trials which you should combine if allowed and the judge will appreciate, and then you’re going to want to address any evidentiary issues as mentioned above.

Review the course of the litigation, see if OC has been mentioning anything that should be in, check with your bar org for common issues and second that you should NOT shotgun plead boilerplate MILs. Make them concise, case specific, and persuasive. Chances are you will outprepare OC

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Additional Posts in Personal Injury Lawyers

Chicago attorneys: what is the base salary of a 3 year associate? What % of fee do they get on cases they bring in? Do they get paid any money on cases they’re working on but didn’t bring in? I know it varies, looking for info based on personal experience/knowledge.

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In an auto accident trial, can you inform the jury in any way that the at-fault driver had insurance? I have a hard time believing a jury would award 7-figure damages if they thought the little old lady defendant had to personally pay. I’m just starting to do PI on the side by myself at my firm, so this is probably a very dumb and obvious question.

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Anyone work for Morgan & Morgan? Do you know if they allow you to work remotely/hybrid? I’d like to apply with them but the closest office is an hour away and I don’t want that commute. I have a young child.

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I know this is a broad question but how much should a 3 year PI attorney going into their 4th year make approx. I’m in Chicago, a range is fine too.

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I received a job offer from a PI firm (MVA and tractor trailer cases) in Houston, Texas; the bonus proposed was 2.5% of attorney’s fees for any cases settled each quarter. We are assigned 50 cases a quarter and the top attorney clears $25K each quarter. This is my first time working at a PI firm. Can anyone share any guidance? Is 2.5% industry standard? Is it realistic to settle/resolve that many cases? I am trying to learn more about this niche before I counter-offer and attempt to negotiate.

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I have a dumb question... I have my first jury trial coming up in a few months. It's a 3-day auto accident trial. I'm the plaintiff attorney. My question is, should I have my client present the entire three days, or am I okay to tell them that they're fine to leave after they testify?

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When y’all have bench trials, what are typical awards?

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