Einhorn and Lorber Published in Texas Bar Journal

Enoch Kever Members, Elana Einhorn and Melissa Lorber, along with Amanda G. Taylor and Maitreya Tomlinson, have been published in the July/August 2023 Texas Bar Journal.

The article, HELP US HELP YOU – Top 10 appellate mistakes in the trial courts, “outlines 10 common mistakes in the trial court that cause problems on appeal,” specifically:


  • Pre-suit Pleadings
    • Not identifying the legal standards early on
    • Not anticipating Texas Citizens Participation Act and Texas Rules of Civil Procedure Rule 91a motions to dismiss early in the pleading process
  • Evidentiary Hearings/Trials
    • Not getting excluded evidence into the record for appellate review
    • Not preserving error on objections
    • Not preserving error on the jury charge
    • Not presenting sufficient evidence of appellate fees
  • Following Entry of Order/Judgment
    • Confusion regarding new trial motions and orders
    • Confusion regarding findings of fact and conclusions of law
    • Confusion regarding finality of judgments
    • Confusion regarding supersedeas