Summary Judgment Motions: Advanced Strategies for Civil Litigation

Weighing the Risk of Showing Your Hand, Leveraging Discovery Tools and Timing, Identifying Inadmissible Evidence

Recording of a 90-minute CLE webinar with Q&A

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Conducted on Tuesday, April 8, 2014

Recorded event now available

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Course Materials

This CLE course will provide litigators with techniques for preparing and presenting successful summary judgment motions. Our panel of experienced litigators will step outside the obvious to explain the nuances in deciding whether and when to file a summary judgment motion, using discovery, timing the motion and more.


Summary judgment is a critical first stage in civil litigation. A successful summary judgment motion will save clients legal expenses and litigation costs, which in business litigation can be in the millions. However, planning and effectively using motions for summary judgment (MSJs) present litigators with a number of challenges.

Counsel must begin to plan for the summary judgment motion at the outset of a case. Attorneys must develop a proficiency in strategically balancing the risk of revealing important elements of a case vs the likelihood of success on the MSJ.

Summary judgment motions aren't boilerplate or template motions and require a litigator to control and integrate discovery. Counsel must also assess the admissibility of evidence and determine whether to address issues on a preemptive basis or wait for the other party's reply brief.

Listen as our distinguished panel reviews the intricate nuances and specialized approaches involved in a successful MSJ practice. They will provide attendees with strategies on deciding whether to file, timing the motion, using discovery and third-party discovery, and more. Our panel will equip attendees with the knowledge to prepare and present motions for summary judgment that assist in saving their clients time and money.



  1. Procedural framework
    1. FRCP 56
  2. Balancing risk v. reward in pursuing MSJ
  3. Timing
  4. Strategic discovery plan
  5. Identifying inadmissible evidence


The panel will review these and other key questions:

  • What must be considered in deciding to pursue a MSJ and in balancing the risk of revealing key trial strategy with the likelihood of success?
  • What strategies must be implemented in performing discovery with a MSJ in mind?
  • How can counsel most effectively make use of third-party discovery?
  • What are the best practices for counsel to anticipate the admissibility of evidence?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Eric S. Oto
Eric S. Oto

Law Offices of Eric S. Oto

Mr. Oto’s has over 27 years’ experience in complex business litigation, professional liability matters,...  |  Read More

Susolik, Edward
Edward Susolik

Callahan & Blaine

Mr. Susolik is known and respected as one of the top insurance bad faith and coverage lawyers in the Western United...  |  Read More

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