Beyond the Evidence Code and the Rules of Procedure, I recommend certain publications to assist in your preparation for both litigation and trial.

This first publication was not available when I practiced law, nevertheless, I have referred to it at various times as a Special Magistrate. The 2021 Florida Handbook on Civil Discovery Practice is available through The Florida Bar. The Circuit and County Judges got together with the Trial Lawyers section of the Florida Bar and put together an invaluable handbook that addresses almost every issue that will come up in your civil or family litigation practice. I specifically recommend reviewing Chapter Five Proper Conduct of Depositions.

Trial Techniques and Trials by Thomas Mauet is in its 11th edition. It is a comprehensive yet concise handbook that covers all aspects of the trial process and includes excellent examples of opening statements, direct and cross-examination, proper questions to lay the predicate for exhibits, expert witnesses, objections, trial prep and strategy, and more. It is available through Aspen Publishing.

Florida Practice and Procedure by Henry Trawick has a lengthy analysis of each of the Florida Rules of Civil Procedure and has a separate chapter for Family Law actions. The 2024 edition is published by the Harrison Company and available through Thomson Reuters. The new edition is over $1000, however, there are plenty of older albeit used editions available online at a reasonable price.

These are the publications that I would recommend to trial lawyers, no matter how many years they have practiced law.