Dan Wade
@dwade6412
Dan Wade
Some important points on preservation of error (from a much more senior attorney than me):
#1: You need to get on the record any objections you may have on jury instructions—and you need to be clear; don’t namby-pamby, and don’t shut up simply b/c you think the judge might get mad;
#2: If you can’t do that on a transcript at a charge conference
... See more“Look, I require pinpoint cites and basically if I start reading a brief and somebody is saying something that's in the record and I'm looking at the cites and it's not in the record, it's over. You only have so much time and every lawyer only has so much credibility. I would just please beg you frankly, you know, . . don't stretch when you brief.
... See moreIn every depo prep, among other things, I tell witnesses that the deposing attorney will surely do certain things. Show you a document that says x. And then take the question away from the document and attempt to establish a universal truth. And when they do that, they will start the question with “so, isn’t it fair to say that.”
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... See moreIn that moment I had a thought, so I jumped in and said something like, “but those are all choices. Customer service doesn’t have to be an underpaid and awful job. Just think about how much it absolutely sucks to do anything related to customer service on the customer end, the automated phone menus and the dialogs and the way you are never talking... See more
Why every fitness influencer is a conservative jagoff
So, next time you are in trial:
- Think about your Rule 50(a) motion from the beginning, and consider drafting it in advance and adding any arguments that arise during trial;
- Don't shove it off on a junior associate without supervision;
- Consider making a written Rule 50(a) motion in addition to your verbal one, for filing after review by all of the
Rule 50(a) Motions Are Terrifying and You Should Be Concerned at Trial
How I overcame a fear of making mistakes.
I spent a period of time where my goal was to plow through work in the cheapest and most disposable way possible. My choice was cardboard—sheets of corrugated cardboard from the streets of Manhattan.
I’d haul it up to my studio in big bundles every day, and put it all over the walls, the floor—even on the... See more
I spent a period of time where my goal was to plow through work in the cheapest and most disposable way possible. My choice was cardboard—sheets of corrugated cardboard from the streets of Manhattan.
I’d haul it up to my studio in big bundles every day, and put it all over the walls, the floor—even on the... See more
Kieran • Following the White-Hot Fire Inside of You
When I get blocked in my work, I just quit.
I used to think that the best thing to do when experiencing a painting block was to put my head down and try to push straight through.
Now I try to think of the word ‘block’ from a different angle. A colon gets blocked; an artist has dry spells. A dry spell is a good sign: it means you’re working. The only... See more
I used to think that the best thing to do when experiencing a painting block was to put my head down and try to push straight through.
Now I try to think of the word ‘block’ from a different angle. A colon gets blocked; an artist has dry spells. A dry spell is a good sign: it means you’re working. The only... See more
Kieran • Following the White-Hot Fire Inside of You
