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Tim Hallahan and other members of The Hecht Training Group offer a practical, one- and one-half day workshop, which combines simulations, an interactive seminar, and demonstration to teach the skills of pre-trial motion practice.


The workshop stresses the "learn-by-doing" method of skills training. To begin the program, the instructor, using a demonstration videotape, lectures on effective techniques of oral advocacy. Then working in small groups, each participant argues two pre-trial motions, either as the moving party or as the respondent. After each argument, the participants are critiqued by faculty "judges," consisting of experienced attorneys from your office working with the instructor. In addition, the arguments can be videotaped for one-on-one review and critique.

During the workshop, in-house faculty members demonstrate the skills of oral argument, using an active case from the office or one of the hypothetical problems provided in the workshop materials. As an alternative, a pre-recorded videotape of an oral argument can be used.

There is no limit on the number of participants; however, the number is contingent upon the number of available in-house faculty. To train the attorneys who serve as in-house faculty in the techniques of observation and critique, a faculty training session precedes the workshop.


In advance of the workshop, participants receive detailed instructions, the five workshop problems, and background resource materials on oral advocacy skills. In addition, in-house faculty members receive teaching notes outlining expected arguments and suggested questions for the faculty "judges" to ask the parties.

The five workshop problems consist of a brief fact pattern, a summary of relevant law (no further legal research is required), and supporting evidence. The five problems include:

•  A motion to dismiss for lack of personal jurisdiction;

•  A motion to compel production of a report after a claim of privilege and/or work product;

•  A motion for summary judgment on a claim of a subsequent purchaser's liability;

•  A motion for injunctive relief to enforce a non-competition covenant; and

•  A motion for injunctive relief to prevent the seizure of collateral after an alleged default on a loan.

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