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Kelly Woodruff of the California Appellate Law Group Kelly Woodruff of the California Appellate Law Group/courtesy photo

Imagine: You have been defending your client in litigation for over two years. You’ve taken dozens of depositions. You’ve reviewed thousands of pages of documents produced in discovery. You now have enough evidence to file a summary judgment motion. You painstakingly prepare a declaration attaching dozens of exhibits, including excerpts from deposition transcripts, emails from plaintiff, and other documents produced in discovery. You file a brilliant memorandum of points and authorities. And you win — judgment for defendant!

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