Author Archive | Ross Guberman, guest-blogging

That Reminds Me: Examples and Analogies

When Utah sued the federal government over the 2000 census, a census-taking technique called “hot-deck imputation” was on the hot seat. Utah was none too happy to have lost a representative based on its population estimate, so it argued that “imputation”—inferring who lives in a residence by looking at like neighbors—was essentially “sampling,” which is […]

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Power Verbs

Here are three sentences from Paul Clement’s Supreme Court brief against the Affordable Care Act’s individual mandate. When you see bolded language, I’ve replaced Clement’s evocative verb choice with typical lawyer talk. Take a stab at guessing what he actually wrote each time: In all events, the federal government gains nothing by asking the Court […]

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Three Tips for Trial Filings

Trial filings are the Ugly Ducklings of written advocacy. Rarely do judges say, “Ross, I just read the most incredible motion in limine” or “Wow, you’ve got to see this memorandum in support of partial summary judgment that I just devoured.” Let’s face it, although most litigators hang around the trial courts, most of the […]

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