January 2022

January 22, 2022 Dearly Beloved: Table of Contents Sometimes, your complaint can be specific enough because of the way you highlighted an attachment to your motion for new trial–but I’d still recommend specifically describing the complaint in the motion Judgment If you announce you are ready to proceed, you will probably have waived the motion […]

January 15, 2022 Dear Friends: Table of Contents Even a constitutional complaint must be timely raised While I won’t profile them here, opinions for the last few weeks reaffirmed that you must make complaint about the following in the trial court Attorney’s fees Evidence Legal Sufficiency Pre and Post Judgment Interest Summary Judgment Blurbs Your

January 8, 2022 Dearly Beloved: Table of Contents Several holdings about the failure to object to a temporary injunction waiving certain complaints–which differs from a complaint that the temporary injunction does not comply with Rule 683, which first can be raised on appeal (Query: is this a distinction which might inform how we characterize our

January 1, 2022 Dearly Beloved: Happy New Year!  I hope this turns out to be your Best Year Yet! Table of Contents You have to comply with other pertinent rules–and even if the court of appeals previously ruled for you before remanding, you have to raise law of the case in your summary judgment response