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July 8, 2025
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Douglas Lang and Katie Kraft on Effective Trial Planning and Error Preservation

Former Justice Douglas Lang, now senior counsel at Thompson Coburn, and partner Katie Kraft recently co-authored an article published in the Summer 2025 edition of The Federal Lawyer. The piece covers critical aspects of comprehensive litigation planning, offering valuable strategies for trial and appellate stages.

Lang and Kraft provide readers with a practical checklist, outlining foundational tasks and strategic considerations for effective litigation. A key focus of their article is error preservation and avoiding pitfalls during trial. They emphasize the crucial early step of marshalling evidence and planning the order of proof, stating, “Knowing what evidence is on hand and identifying what evidence is needed to prove one’s case is, perhaps, the most critical early step for a litigation plan.”

They underscore the importance of meticulous preparation: “Effective trial and appellate practice are accomplished by hard work and attention to detail. This must include meticulous planning of each stage of the litigation and expressly for preservation of error for review. Without careful and thorough attention to error preservation, an appeal is lost before it begins.”

Read the full article here.

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