Trial counsel excel at collecting and presenting facts, at preparing and cross-examining witnesses, and at the complex task of bringing everything together for a trial.  But they often lack the time or special skills to develop the legal arguments that can shape outcomes.

How GMSR Helps                                                                                                      

GMSR strengthens a client’s trial court team by:

  • Contributing ideas on big-picture legal strategy and how to best posture the case for appeal – win or lose;
  • Shaping the case with demurrers, motions to dismiss, and motions for summary judgment or summary adjudication;
  • Preparing, opposing, and arguing motions in limine;
  • Drafting and opposing jury instructions and special verdict forms;
  • Drafting trial briefs;
  • Devising “pocket” trial briefs on specific issues – helping to guide trial judges and preserve the record more effectively than oral objections alone;
  • Ensuring preservation of critical issues for appeal; and
  • Preparing and arguing post-trial motions.

In the crucible of trial, a lawyer focused on the next step – a potential appeal – confers a powerful advantage.  GMSR’s appellate lawyers bring unparalleled research and writing skills, strategic thinking, and the kind of judgment that comes from having seen so many situations before.  GMSR’s presence alone conveys its client’s commitment to seeing a case through to the best outcome or resolution.  Involving GMSR at the trial court level helps posture a case for success on appeal.


It’s never too early for persuasive writing and legal argument.  But it is sometimes too late.


GMSR has helped clients clinch victory at key moments in the trial court, including defeating demurrers; drafting successful summary judgment motions in high stakes cases; knocking out key experts with targeted motions in limine; and persuading the trial court to accept or reject critical jury instructions – sometimes causing an opposing party to abandon a claim on the eve of trial.