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John Day

Let me suggest an addition: Trial Error. This section serves as a place to write down all potentially reversible error. Do not write down every ruling that goes against you, but only those errors that you would later include on a motion for new trial if you lose the trial. Write down the date and time of the error so that you can quickly find it later in the transcript. Use of such a list reduces the likelihood of failing to include an itemof error on a motion for new trial which, in many jurisdictions, results in a waiver of that issue as a ground for appeal.

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