What does every good plaintiffs lawyer need to know when it comes to drafting (motions, complaints, etc.)?

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Only do what’s necessary on the offensive. In complaints, don’t put more than necessary and be vague as possible. You don’t want a variance after trial over something stupid

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This question is too vague. Complaints and motions are totally different and require knowing different things. Also depends somewhere on your state. I’d say follow the rules, check local rules, do you need proposed order, TOC, TOA etc? For complaints at least in California I agree with keeping it simple without much detail just make sure to allege every element of your case based on the elements of the jury instructions for each cause of action.

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Also defense lawyers usually screw you in discovery responses so you need to send a meet and confer letter complaining or you’ll never get the documents you need.

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Very broad question and would this public forum not potentially educate the dark side? Feel free to call or text me if you want to talk strategy 9196160603

Purposefully broad—just looking for tips and tricks on how to avoid shitting the bed. Just starting out with a reputable midsize firm. They have support staff handling prelit; attorney oversees process but truly steps in when it is time to file. Just trying to get ahead of the curve here.

Hit only the critical points—get to the point. Save the rest for oral argument.

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