Prioritize for Persuasion
When drafting an appellant’s opening brief, it’s tempting to raise every conceivable error. But the most effective opening briefs identify the issues that matter most and present them in a logical structure that leads the court to the relief you are requesting. Here are some
Preserving Evidentiary Issues
An appellate argument that the trial court erred in admitting or excluding evidence requires a solid foundation in the trial court record. Your evidence. If the court is inclined to exclude your evidence, make an offer of proof that (1) describes the evidence in detail,
How Appeals Differ From Trial Court Proceedings
Most lawyers know that an “appeal is not a do-over.” But it’s crucial to understand just how fundamentally different the legal process is. In trial court, the questions are: “What happened, who is credible, and what, if any, remedy is available?” On appeal, the question
Time is Precious: Balancing Urgency & Quality
Unless the deadline is set by statute, writ relief can usually be sought within 60 days of the trial court’s order. But sometimes the order itself or other circumstances impose a much shorter, real-world deadline to obtain writ relief. For example, as a practical matter, an order
The Collateral-Order Doctrine: A Narrow Path to Early Review
Under California’s “one final judgment” rule, an aggrieved party generally can’t file an appeal until the trial court has resolved every claim and cross-claim between that party and the opponent. An important exception to that rule is the collateral-order doctrine, which permits an early appeal
Post-Judgment Motions During An Appeal?
An appeal divests the trial court of jurisdiction to take certain actions regarding the appealed judgment. There are many nuances in applying this rule. Here’s an overview of how a pending appeal affects the trial court’s power to rule on post-judgment motions: New trial motion. The
Striking the Right Tone
In appeals, selecting the right tone is as essential as selecting appellate issues. It is a given that every appellate brief must be calm and respectful. But persuading the court of appeal also depends on matching the tone of your brief to the needs of your case. Some
Citing Trial Court Decisions
Free reporting services have flooded the Internet with trial court orders, and Westlaw has also provided much easier access to them in recent years. This has led lawyers to cite them in briefs far more often. But in California appeals, that’s usually a mistake. Orders
Don’t Back-Burner The Jury Instructions
Busy litigation teams often defer drafting jury instructions until the eve of trial, or sometimes even mid-trial. But preparing an internal set of draft instructions on your main claims or defenses at the beginning of a case has significant benefits as the case progresses. Among
Appealing Too Soon
Appeals as-of-right are statutory and subject to strict timing constraints in California. Most lawyers know the fatal consequence of waiting too long to notice an appeal. But it’s also possible to notice an appeal too early – causing practical problems that are serious, even though
Who We Serve
Whether on appeal, assisting trial counsel, or advising government officials contemplating legislative action, GMSR provides unique insight into the complex laws that impact public entities.
GMSR represents insurers on appeal effectively and efficiently. We also collaborate with our clients and trial counsel on strategy for coverage, contribution and bad faith litigation before appeals begin.
GMSR offers corporate clients objective assessments on appeal, based on a deep understanding of the limitations and opportunities of appellate review.
The firm’s lawyers are team players, collaborating with trial counsel at any level from legal strategy to writing or editing trial court motions and appellate briefs.
GMSR vigorously advocates the rights of individual plaintiffs and defendants, in both state and federal appellate courts.
As part of GMSR’s long-standing commitment to social justice and equality, GMSR provides pro bono appellate services to individuals and to community organizations on issues of concern.
© 2026 Greines, Martin, Stein & Richland LLP.
All rights reserved. Disclaimer - Attorney advertising. Prior results do not guarantee a similar outcome.
Los Angeles
6420 Wilshire Boulevard, Suite 1100
Los Angeles, California 90048
p: (310) 859 7811 | f: (310) 276 5261
San Francisco
50 California Street, Suite 1500
San Francisco, CA 94111
p: (415) 315 1774
Orange County
555 Anton Blvd, Suite 150
Costa Mesa, CA 92626
P: (310) 859-7811
We welcome your inquiry. However, sending us an email does not create an attorney-client relationship. For that reason, you should not send us any kind of confidential information. Until we have agreed to represent you, we cannot be obligated to keep it confidential.