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Post Trial Motions in California


In both jury and non-jury matters, preparing focused and persuasive post-trial motions can be immensely important: not only do such motions give litigants one final chance to persuade the court to their position, but they also serve as an essential vehicle to ensure a complete record exists for any appeal. Yet, the rules that govern post-trial motions are complex and often misunderstood. To add potential confusion, those rules emanate from several sources: statutes located in different parts of the Code of Civil Procedure, Rules of Court that govern different motions and appeals, and case law that has attempted to interpret those statutes and rules and bring clarity to the process.

This 3-1/2 hour post-trial motions program, chaired by appellate specialist Paul D. Fogel, the head of Reed Smith’s appellate group, will be presented by practitioners and judges with extensive experience handling post-trial motions. The seminar will highlight many of the issues presented by the following post-trial motions in jury and non-jury matters: motions for new trial, motions for judgment notwithstanding the verdict, motions to vacate, motions for fees and costs, and motions for stays. The panelists will also discuss the all-important statement of decision procedure whose understanding is essential to any litigant desirous of pursuing an appeal after a bench trial or lengthy bench proceeding.

Visit the Bridgeport website for more information about this conference.


8:30 - 9:00 - Registration & Continental Breakfast

9:00 - 10:15 - Post Trial Motions following a Jury Trial – New Trials, JNOV

  • Hon. Winifred Y. Smith, Alameda County Superior Court
  • Paul D. Fogel, Reed Smith LLP
  • Asim Bhansali, Keker & Van Nest

10:30-11:30 - Post Trial Motions following a Bench Trial

  • Hon. Ioana Petrou, Alameda County Superior Court
  • David de Jesus, Reed Smith LLP
  • Joshua Lipshutz, Gibson Dunn & Crutcher

11:40 - 12:30 - Motions for Fees, Costs, And Postjudgment Stays

  • Hon. John True, Alameda County Superior Court
  • David de Jesus, Reed Smith LLP
  • Michael Ram, Ram, Olson, Cereghino & Kopczynski LLP

Location: Hyatt Regency San Francisco, 5 Embarcadero, San Francisco 94111