Seminar Outline Trial & Appellate Court's Perspective: Practical Tips Practical Tips from an Appellate Lawyer Charge Error Presevation: Say It Early, Say It Often, or Don't Say It At All? Non-Charge Preservation of Error The trial lawyer is charged with the responsibility of preparing and filing pleadings for her client, investigating the facts, researching the law, conducting discovery, pursuing or defending motions, exploring settlement possibilities, and, if necessary, trying the case. If the case is tried successfully, he must also draft a judgment and defend against post-trial motions. If the case is tried unsuccessfully, she is generally in charge of preparing, filing, and pursuing post-trial motions. The way in which these activities are conducted will not only affect the outcome of the case in the trial court, it will also affect the outcome of any appeal. During the course of the trial court proceedings, the parties generally do not know if the case will end up before an appellate court. It’s always best, however, to assume that it will. During the trial court phase of a case, therefore, it’s important not only to preserve error, but also to do other things that can enhance your client’s chances on appeal. The purpose of this paper is to present, from the perspective of an appellate practitioner, some ideas about what you can do in the trial court to make any future appeal cleaner, more cogent, and more “appealing” to an appellate court.