Civil Litigation Series | The Middle Stages – Close of Pleadings to Trial

From the time the pleadings close, fresh challenges arise and new decisions need to be made both leading up to and during trial. Each decision potentially impacts the next stage, or that two or three steps further on. This webinar will focus upon the steps in a proceeding after the pleadings have closed, and written evidence has been exchanged, through to the hearing. The presenters will discuss the usual steps that occur and issues that arise with them.

Who Should Attend?

Litigators up to intermediate level and those more senior seeking a refresher. General practitioners who do some litigation work will also benefit from attending.

  • Enhance your understanding of the steps between the exchange of written evidence and the commencement of trial and issues that potentially arise in each case.
  • Understand the considerations and steps involved in objecting to other parties’ evidence.
  • Reinforce the importance of preparing your witnesses for trial and the means of doing so.
  • Understand common practical issues arising from use of electronic bundles/VMR and how to deal with them.
  • Consider different approaches to enhance the presentation of your case with visual aids.
  • Evaluate opening submissions, chronologies and different approaches to preparing them.
  • Understand the importance of your theory of the case and your audience.
  • Discuss oral evidence, its significance, and objections during trial.
  • Consider approaches to cross-examination and your preparation for it.
  • Consider re-examination, when it is necessary, and how it might be best tackled.
  • Consider the issues that can arise during a trial, such as the emergence of new, unexpected, issues and evidence and how they might be accommodated.
  • Discuss finalising the closing submissions and the treatment of the evidence in them.


Linda Hui
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Linda is a civil litigator who commenced practice in 2012.  She acts for insurers on material damage, general liability, professional liability claims and subrogated recoveries.  Before joining McElroys she worked for the regulatory and insolvency practice of a national litigation firm, and before that in the insurance team of a large international firm.

She has appeared as sole or principal counsel in the High Court and as junior counsel in the Court of Appeal and the Supreme Court.

Sean McAnally
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Sean has been involved with litigation in New Zealand and the Cook Islands for some 23 years.  While he now predominantly acts on civil and commercial cases, his background includes criminal, family and regulatory matters. He has appeared in all levels of the court system including the Privy Council and also appears in specialist tribunals such as the Health Practitioners’ Disciplinary Tribunal and the Real Estate Agents’ Disciplinary Tribunal.  Before joining the independent bar in 2022, he spent 20 years at Keegan Alexander, 13 of those as a partner.



Pricing Details

Ticket Price

Member: $190 GST
Non-Member: $270 GST


Registration Close Date