Jury Instructions

Jun 11, 2024 Alana H. Rotter
Four Ways To Create A Clear Record For Appeal

One key to success on appeal is creating a clear and complete record.  Here are ways to create such a record that are often overlooked in the heat of trial: Ask the court reporter to transcribe sidebars and in-chambers conferences.  If that’s not possible, summarize

Apr 12, 2023 Gary J. Wax
To Gain An Edge, Control The Document

During trial, there are several opportunities to obtain an edge over opponents simply by offering to prepare or edit documents—in particular, jury instructions and verdict forms.  Here are some tips to obtain and maintain an advantage: Don’t simply submit a list of the CACI form

First Motor Group of Encino, LLC et al. v. Encino Motorcars, LLC et al. (Mar. 10, 2023, B303094) 2023 WL 2445641

Court of Appeal affirms defense verdict in $40 million case alleging false financial statements, finding no prejudice from claimed instructional error

Dec 12, 2022 Alana H. Rotter
CACI Instructions Are Not Always Correct

The Judicial Council of California Civil Jury Instructions (i.e., CACI instructions) get heavy use in California’s trial courts, both because they are convenient and because some judges insist on them.  But beware:  CACI instructions have their limits.  Those limits include: CACI instructions are not themselves

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.

Read More

Where coverage may exist, GMSR represents insureds on appeal effectively and efficiently. Where it does not, the firm protects insurers’ right to deny claims.

Read More

GMSR offers corporate clients objective assessments on appeal, based on a deep understanding of the limitations and opportunities of appellate review.

Read More

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.

Read More

GMSR vigorously advocates the rights of individual plaintiffs and defendants, in both state and federal appellate courts.

Read More

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.

Read More