Gary Zeidwig doesn’t think so, at least not all the time. Zeidwig, an award-winning lawyer, reveals that there are some cases where an individual can move forward pro se, (for oneself) that is, advocating without an attorney and defending or fighting for their rights on their own behalf, and that it’s not only acceptable but relatively safe to do so.
The clinic has also introduced a unique program that solicits junior lawyers at firms to take or defend depositions for pro se litigants on a pro bono basis. As a former litigator in private practice Tarnofsky recognized that in high stakes litigation, clients often want experienced lawyers handling depositions.  This program has been welcomed by a number of large New York City law firms an opportunity to train the next generation of lawyers. For pro se litigants it means not having to face a tough deposition on their own, and having a far better chance to tell their stories and make the best case or mount the best defense possible.
If you’re a law student—or plan to go to law school—this book is a useful and easy-to follow guide to the basics of civil procedure and litigation, from initial pleadings and discovery to appeal. The knowledge of general court procedures and fluency with legal terminology that you will gain from reading this book will help you successfully transition to law school and enhance your understanding of assigned casebook readings.

7. At least some commentators have expressed concern that allocating more legal resources to pro se civil litigants might take away from resources needed for indigent criminal defense. See Barton and Bibas, 160 U Pa L Rev at 980–81 (cited in note 5). It is important, however, to recognize that legal resources also may trade off with nonlegal resources, and an analysis accounting for these trade-offs may make the economics of expanded legal resources for pro se litigants look more attractive. Additional money spent on lawyers or pro se assistance might be more economical than it first appears if, for example, additional state spending in an eviction or wrongful termination proceeding saves the government from paying for homeless shelters or welfare assistance at a later date.

I've been accused of overstating former Vice President Joe Biden's potential in the 2020 presidential primary. After all, he's a gaffe-prone septuagenarian who touts occupational licensing reform and maintaining our private health insurance industry. And he's in a Democratic Party led by a socialist who honeymooned in the Soviet Union and a 29-year-old former bartender who believes that "like, the world will end in 12 years" because of climate change.
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Pro se representation presents unique but not insurmountable challenges for claimants and the legal system. In Louisiana, for instance, the Louisiana Court of Appeals tracks the results of pro se appeals against represented appeals. In 2000, 7% of writs in civil appeals submitted to the court pro se were granted, compared to 46% of writs submitted by counsel. In criminal cases the ratio is closer - 34% of pro se writs were granted, compared with 45% of writs submitted by counsel.[38] According to Erica J. Hashimoto, an assistant professor at the Georgia School of Law,:

A fellow advocate member of DAC, our advocacy group, filed her Pro Se in Federal District Court, after waiting and waiting for DOJ to respond. She lives on a low fixed income, and was able to waive the filing fee. Within a week, she received her notification of receipt that her case is now pending in federal court. At the same time she received notification that the inaccessible business was being served the complaint by a federal marshal. Shortly after that, she received a letter from the attorney for the inaccessible business stating that they wanted to settle out of court. Of course!! We settled for full compliance with the ADA.
Department of Social Services,37 the appellant argued that failing to provide counsel in a civil suit that would terminate parental rights violated the Due Process Clause.38 A 5–4 majority on the Supreme Court held that there was no general right to appointment of counsel in parental termination proceedings despite the importance of the right involved. The Court explained that a
Tables 2E and 2F, the final tables in this Part, examine how win rates for pro se litigants vary across different types of cases. The win ratios in Table 2E compare the probability of a plaintiff winning when both parties are represented to the probability of a plaintiff winning when the plaintiff is a pro se plaintiff but the defendant is represented. In the column “Plaint Rep’d / Plaint Pro Se,” the number 2.0 would mean that plaintiffs win twice as often when both parties are represented as compared to cases in which the plaintiff is pro se. The higher the number, the better represented litigants fare relative to pro se litigants.
The empirical findings in Parts II, III, and IV have a number of potentially important implications for the future of pro se litigation. However, before considering the policy implications, this Comment must reiterate the limits of this analysis. First, this analysis centers only on case outcomes. Further analysis—for example, a survey-based analysis that asks litigants how they feel after they went through the litigation process—may reveal substantial benefits stemming from pro se reforms that this study does not find. Second, this analysis shows only that the reforms highlighted throughout this analysis have not impacted case outcomes for nonprisoner pro se litigants on average across courts. However, it might be the case that certain courts have been much more successful in implementing these reforms than others, and this analysis masks those successes. Moreover, limitations on survey data, coupled with the fact that litigation frequently takes years to resolve, mean that most of the data analyzed in this
If you go by calls and emails Jurisdictionary receives, there's good reason for this! Lawyers who bail at the last minute. Lawyers who don't know what they're doing. And, worst of all, lawyers wishing to curry favor with judges, afraid to stand up to the buffalo in the black robe and demand their clients' rights by making timely objections and threatening appeal.
In contrast, the results for services intended to help pro se litigants obtain representation are somewhat less clear. Again, the resultant “improvements” in win rates look more like statistical noise than meaningful impacts, but there is arguably more room for contrary interpretations.113 However, while those reforms are no doubt also advocated by many seeking an alternative to civil Gideon, they concern increased access to counsel instead of substitutes for access to counsel. Thus, these kinds of reforms do not resemble the types of reforms suggested by the Supreme Court in Turner nor by most commentators discussing civil
One newspaper report from the time suggests Parker did fine, though it was clear he was an amateur. He arrived with a thick pile of notes, wagged his fingers at the justices, and wore striped pants and a cutaway jacket. That was what all lawyers once wore to argue at the court, but it had fallen out of favor for all but government lawyers by the time Parker appeared before the court.
Tables 2E and 2F, the final tables in this Part, examine how win rates for pro se litigants vary across different types of cases. The win ratios in Table 2E compare the probability of a plaintiff winning when both parties are represented to the probability of a plaintiff winning when the plaintiff is a pro se plaintiff but the defendant is represented. In the column “Plaint Rep’d / Plaint Pro Se,” the number 2.0 would mean that plaintiffs win twice as often when both parties are represented as compared to cases in which the plaintiff is pro se. The higher the number, the better represented litigants fare relative to pro se litigants.

One newspaper report from the time suggests Parker did fine, though it was clear he was an amateur. He arrived with a thick pile of notes, wagged his fingers at the justices, and wore striped pants and a cutaway jacket. That was what all lawyers once wore to argue at the court, but it had fallen out of favor for all but government lawyers by the time Parker appeared before the court.
Congress also has a role. In extreme cases it has the power to remove judges, of course. But short of that, it can at least underscore the seriousness of the rights it established for litigants in the Judiciary Act. Whether through binding or nonbinding language on the topic, Congress can make clear that complaints about violations of the rights of pro se litigants must be taken very seriously by judicial councils.
So, you have to decide what your goal is: (1) To post your complaint on the web in all its vitriolic splendor and go down in a blaze of glory or (2) to win your case. If its the former, go for it! If its the latter, get some help to draft a complaint in law talk, keep it simple, and go for the bucks you need to survive. You can do that, and still keep the street war going in a forum other than the courtroom. That's the win-win approach.
When you go into a foreign country and want to communicate with the inhabitants, you have to talk THEIR lingo. Courtrooms are a foreign country and they have their own language. "Complaint language" (or "law talk") is what they call it. If you don't use it in your pleadings (that's what documents you file with the court are), you will not only not be listened to and taken seriously, you will not be HEARD. They will literally not SEE the words on the page if they are not written in their "language."

5. If you or your group did anything to inform that particular business owner of his violation, then you might want to make that paragraph 19. It might read like this, "During the summer of 1997, the Louisville CIL visited the business in question, and spoke to the owner. The owner could easily make his business accessible but has chosen not to comply with the Americans with Disabilities Act."
Massachusetts District Court and Prospects for the Future, 126 Harv L Rev 901, 914 n 57 (2013) (discussing a recent American Bar Association (ABA) recommendation to provide pro bono counsel to civil litigants in cases involving “direct threats to the provisions of basic human needs, including shelter”). The ABA has also recommended appointed counsel for cases involving sustenance, safety, health, child custody, or removal proceedings, highlighting the breadth of potential “basic needs” that some advocates believe merit the appointment of counsel in civil pro se litigation. See, for example, Jaya Ramji-Nogales, Andrew I. Schoenholtz, and Philip G. Schrag, Refugee Roulette: Disparities in Asylum
Tables 2E and 2F show that there is considerable variance in the outcomes of different types of cases for both represented and pro se litigants. When plaintiffs proceed pro se, they win somewhere between 2 and 11 percent of cases, depending on the nature of the suit. When the defendant is pro se and the plaintiff is represented, the plaintiff wins somewhere between 43 percent and 93 percent of cases,89 depending on the nature of the suit. This substantial variance is not confined to pro se litigants. Even when both parties are represented, there is wide variance in the percentages of cases won by plaintiffs, ranging from just 13 percent in products liability and employment discrimination cases to 77 percent in property cases.90 But in essentially all categories, pro se litigants fare far worse than represented litigants.
Also, I don’t know what this obligation is to give access to justice that is apparently on the shoulders of individual lawyers. I only know of the 6th Amendment right to an attorney for defendants in a criminal trial, in which case any lawyer could be appointed to represent a defendant; I know of no other obligation to make legal services available to everyone on demand. But you can’t seriously tell me that you don’t pit pro se litigants against lawyers and publish the articles you do. I know some lawyers who are pretty burnt out dealing with pro se nonsense, and I know some who are more generous to those who play lawyer for themselves, but when your opposing counsel is a pro se litigant who can’t distinguish you from your client, or doesn’t understand why you’re representing your client vigorously and then goes on the defense, you wish you could just tell them what is obvious to you: it’s not about them. For example, I might be hesitant to encourage Tanya here to represent herself since she doesn’t seem to understand the difference between pro bono and contingency and statutes and case law, and that she hasn’t actually found any case law yet before deciding to pursue her lawsuit on her own and presenting what may be a matter of first impression, but that’s not my business…
I am an Arizona attorney. AVVO does not pay us for our responses. Simply because I responded to your question does not mean I am your attorney. In Arizona a non-lawyer is held to the same standards as an attorney so there are dangers to representing yourself. This is for informational purposes only and should not be considered as legal advice. If you require legal assistance an in depth discussion of your case is needed as there are many other issues to consider such as defenses, statute of limitations, etc.
Unfortunately, with fees charged by lawyers commonly running in excess of $150 an hour, it may not make economic sense—or even be financially possible—for you to hire a lawyer. Even if you win and are able to collect what the other side owes you, the lawyer’s fees may devour much of your gain. As a result, representing yourself in court or dropping your claim or defense altogether may be your only realistic alternatives.
From Figure 1, it’s difficult to tell whether there is a trend in EDNY meaningfully different from the trend seen in other New York district courts. To investigate this further, this Comment runs the logistic regression described above. Table 4 displays the results of that regression. Because the outcome variable is whether a plaintiff wins or loses a particular case, and each of the independent variables in this regression is a binary dummy variable, the coefficients describe the change in the probability of a case outcome when the variable is set to 1 instead of 0. Hence, a coefficient of 0.5 on the variable “EDNY Reform Dummy” would imply that EDNY Reform increased the chances of a pro se plaintiff winning a case by 0.5 percent.
Find out what your jurisdiction does. If they don’t have them, it’s worth it to bring your own. If a hearing means anything to you, the money you shell out for a court reporter will pay back in spades. If it’s difficult to pay for a court reporter, try to stretch those hearings out as long as you can. If you’re in a multi-year case, you might have a hearing only 3 times per year anyway. If you find you’re having more and can’t afford it, prioritize them. This also helps you think strategically about your case.
The United States District Court for the District of Idaho have prepared this handbook specifically for the person who has chosen, for whatever reason, to represent himself/herself as a party to a lawsuit: the pro se litigant. The purpose of this handbook is to provide the pro se litigant with a practical and informative initial resource that will assist in the decision-making process and in the filing of a lawsuit when choosing not to retain the aid of a licensed attorney...
Table 3B—providing forms and handbooks as well as individual case assistance, for instance. Because this reform effort is different from those that Part III discusses, it’s hard to directly compare them. But both sets of reforms fit into a similar broad bucket: attempts by courts to improve the pro se litigation process by facilitating simpler and more convenient interactions between pro se litigants and the courts.
When pro se litigants feel they are being shut out from the process or that their voices are being stifled, these challenges—and the accompanying risks—are amplified. In fact, studies show that notions of fairness heavily influence and guide pro se litigants. Id. at 4. Indeed, “research has repeatedly established that when litigants perceive that a decision-making process is fair, they are more likely to be satisfied with the outcome.” Self-Represented Litigation Network, Handling Cases Involving Self-Represented Litigants: A National Bench Guide for Judges 2–4 (2008).

But this passage reminds us of the continuing tradition of morning dress for the Solicitor General’s office before the Supreme Court. If it already looked stupid in 1948, it definitely looks stupid now. Adhering to tradition for the mere sake of tradition is small-minded. After Elena Kagan dumped the practice — since wearing what is essentially a tuxedo is less than flattering for a woman — there was some reason to believe it would join powdered wigs in the dustbin of American legal history. No such luck.
*** LEGAL DISCLAIMER I am licensed to practice law in the State of Michigan and have offices in Wayne and Ingham Counties. My practice is focused in the areas of estate planning and probate administration. I am ethically required to state that the above answer does not create an attorney/client relationship. These responses should be considered general legal education and are intended to provide general information about the question asked. Frequently, the question does not include important facts that, if known, could significantly change the answer. Information provided on this site should not be used as a substitute for competent legal advice from a licensed attorney that practices in your state. The law changes frequently and varies from state to state. If I refer to your state's laws, you should not rely on what I say; I just did a quick Internet search and found something that looked relevant that I hoped you would find helpful. You should verify and confirm any information provided with an attorney licensed in your state.

Christa Adkins, the owner of Pro Se One Stop Legal Document Services, LLC, offers highly personalized services to her customers because she has stood in their shoes and knows the fears and frustrations of navigating the legal system alone. Christa is not an attorney, but dedicates her heart and soul to helping other pro se litigants navigate the legal system and fill out their legal documents and forms. Christa has been highly successful in her own pro se endeavors. In 2016, she took her first appeal to the Third District Court of Appeal and successfully had the trial court reversed. Additionally, in 2016 she filed a successful pro se motion for disqualification of the trial judge and the trial judge was removed from her case. In 2017 Christa successfully submitted a pro se Petition for Writ of Certiorari to the Third District Court of Appeal. Her petition was granted.

Importantly, this Comment does not suggest that these reforms have been failures. These reforms may have improved the pro se litigation process by making it feel more humane and easier to understand and by giving litigants a stronger sense that their concerns have been heard. Moreover, these reforms may still ease the burden of pro se litigation on courts by helping courts understand the issues involved more clearly or by moving cases through the judicial system more quickly. The analysis does suggest, however, that district court reforms have been ineffective in improving case outcomes for pro se litigants, and alternative approaches should be considered.
Does my ex have a child custody lawyer? Although the justice system permits parents to represent themselves, we often advise parents to reconsider self-representation if the other parent will be represented by counsel. Parents represented by counsel could be in a more advantageous position. An attorney who understands family law will have specific knowledge that a lay person may lack.
103. The concern with omitted variable bias is that some other variable not included in the model explains both the independent and dependent variable in the model. For example, in this case there could be an “omitted variable” measuring how much courts care about protecting pro se litigants. A court with judges who care a lot about protecting pro se litigants may implement many pro se reforms and also have favorable case outcomes for pro se litigants because the judges are favorable to pro se litigants. Though it is difficult to rule out all omitted variables, in this case the widespread implementation of at least some reforms, coupled with the significant variation in which and how many are implemented by each court, suggests this kind of omitted variable is unlikely. For more discussion of omitted variable bias, see generally Kevin A. Clarke, The Phantom Menace: Omitted Variable Bias in Econometric Research, 22 Conflict Mgmt & Peace Sci 341 (2005).
When you interview a potential legal coach, ask about all fees and costs—including the initial interview. It obviously defeats your purpose if you have to spend more to consult a legal coach than you would to hire a lawyer to handle your entire case. Typically, lawyers use hourly, fixed, or contingency fee arrangements. Most likely, someone serving as your legal coach will charge you by the hour.
Oh my Lord Sonja, you’re my new hero! I went at it with an attorney on Avvo; I asked a legal question and he more or less belittled me for thinking that I had a case and then for thinking that I could actually handle it on my own. This guy was a real jerk! l know I have a winning case but there are not many lawyers in my area that are familiar enough with the statutes to take it pro bono and therefore take the risk. Even the legal opinions that I’ve read say the case law is sparse. Thank you for standing up for pro se litigants and setting the record straight.
This book is designed both to increase your overall understanding of the litigation process and to provide detailed advice about each stage of trial. Unless you are ­already in the midst of trial and need to refer to a particular chapter immediately, begin preparing to represent yourself by read­ing through the book as a whole. As you become familiar with the litigation process, you will understand the significance of procedures and techniques that may initially seem peculiar or unnecessary.
For instance, assume that you want to ask for a jury trial and that your local rule requires a jury trial request to be made 30 days after the initial pleadings are filed. If you miss that deadline, you will not have a jury trial unless you go through a laborious process to request an extension of time to file your demand and the judge is willing to make an exception (but don’t count on it!).
81. Some reasons that these reforms may impact prisoners differently from nonprisoners include: differences in the types of cases brought, potentially different access to legal resources (depending on the availability of legal materials in prison), different judicial attitudes toward prisoner and nonprisoner pro se litigants, or different levels of access to counsel. Note that this Comment does not definitively suggest these reforms impact nonprisoner and prisoner pro se litigants differently. Instead, it merely suggests there may be differences and limits the scope of this analysis to nonprisoner pro se litigants.
Though arbitration proceedings are generally less formal than trials, most of the principles ­described in this book also apply to arbitration. As in a trial, you and your adversary present evidence to the arbitrator through your own testimony and the testimony of witnesses. Like a judge, an arbitrator evaluates the credibility and legal significance of evidence to decide whether you win or lose the case.

Do I have a basic understanding of how court procedures work? Custody hearings, and court procedures in general, can be quite confusing for first-timers. Parents considering pro se representation usually benefit from attending a couple of court hearings in advance, just to become more familiar with what to expect in court and what proper court etiquette looks like. (And remember: any questions you have about proper court procedures can always be addressed to the court clerk. So seek that person out and develop a friendly rapport with him or her.)


Under New York Rule of Professional Conduct 1.2, as part of getting informed client consent, lawyers must disclose the reasonably foreseeable consequences of limiting the scope of representation. If it’s reasonably foreseeable that during the course of representation, additional legal services may be necessary, limited-scope lawyers must tell clients that they may need to hire separate counsel, which could result in delay, additional expense, and complications.

People who can't afford a lawyer are a rebuke to the organized bar's monopoly over legal services, because that monopoly is morally--if not legally--justified only if the legal profession is able to provide affordable justice for all. The lawyer bias against the self-represented is a clear case of blaming the victim--even though for years, the ABA has admitted that 100 million Americans can't afford lawyers.


The AO dataset was created for administrative purposes rather than research, and the reliability of some of the fields kept in the dataset can be uncertain, as shown in a 2003 study of the AO dataset.141 However, this 2003 empirical analysis of the AO dataset suggests that win rates, the key outcome variable used in this analysis, can be deduced reliably from the AO dataset.142 That 2003 study concludes that when “judgment is entered for plaintiff or defendant (at least in cases coded with nonzero-awards) the reported victor is overwhelmingly accurate” and thus that analysis based on win rates in the AO dataset is appropriate.143

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If you represent yourself in an admin­istrative hearing you should be as respect­ful to the ALJ as you would be to a judge, even though the former wears a suit and the latter a robe. Moreover, whether you address your arguments to a judge or an ALJ, you have the same need to present a clear and persuasive case. Make sure you understand the basis of an agency’s action, or what evidence you need to produce to uphold your claim. Also, any witnesses you rely on should attend the hearing, and you should be ready to support your claim with documents and records.

The best way for a lawyer to understand bias against the self-represented litigant is to become one, an experience I recently went through in a civil proceeding. Even before the judge examined my papers or knew what I was seeking (and whether I was on track to achieve it), he expressed deep skepticism that I could competently handle the case myself. After I stood my ground, the judge warned me that I would be held responsible for meticulously complying with every court rule. Lawyers can also learn a lot by coaching a self-represented person through a judicial procedure. Very quickly, most lawyer-coaches come to appreciate how badly the self-represented are treated by court clerks and judges.
There are a few potential omitted variables that this analysis is unable to capture. One possible issue is changing caseloads in each district over time. If the composition of EDNY’s pro se docket shifted in a different way than New York’s other district courts in the years surrounding the reform, that may hide the impact of EDNY’s reforms. Another possibility is that noncourt legal actors may have changed their strategies in response to EDNY reforms. If, for example, outside legal aid clinics started shifting their resources to non-EDNY courts in response to this reform, possibly because those clinics knew that pro se litigants would receive adequate assistance in EDNY due to the reforms, that may also mask the impact of these reforms in EDNY. Finally, because this analysis compares the outcomes of pro se litigation in EDNY with outcomes of pro se litigation in the other New York district courts, if those district courts also made improvements to the pro se litigation process during this time period, the analysis might understate the effect of the EDNY reforms.
However, this book cannot serve as a complete guide to all the rules you need to know. For one thing, the exact rule in your court system may be somewhat different from the example we give. In that event, knowing about another similar rule—either a federal rule or another state’s rule—can help you locate the rule in your state. (See Chapter 23 for information on doing your own legal ­research.) Also, each court system has its own procedural rules that, though important, cannot be covered in this book. For example, local court rules set time limits for filing various kinds of documents and page limits on the length of those documents. You will have to learn and comply with these local requirements.
Knowing ahead of time that you may encounter a hostile attitude is the best weapon against it. Read and study this book and other legal resources, many of which are available free online or in your local library. Learn how to prepare and present a persuasive case and follow the proper procedures for the Clerk’s Office and the courtroom. If you believe that court personnel at any level are being rude to you, be courteous and professional in ­return, even as you insist upon fair treatment. By knowing and following court rules and courtroom techniques, you can often earn the respect of the judge and the others who work in the courtroom. As a result, you may well find that they will go out of their way to help you.
Commentators have seen Turner as a complete rejection of civil Gideon, effectively foreclosing the possibility of an expanded right to counsel in civil litigation, at least for the foreseeable future.44 However, commentators have also seen the holding in Turner—that due process requires trial courts to protect pro se litigants’ rights via procedural safeguards—as a nod toward a new and potentially more fruitful approach to pro se litigation: reforms in trial courts.45

116. A difference-in-differences analysis is an analysis that looks at two samples (here, EDNY pro se litigant outcomes and non-EDNY pro se litigant outcomes) and compares the difference in the average result between those two groups before and after a treatment. This analysis compares the difference between EDNY and non-EDNY pro se litigant outcomes before the pro se reform with the difference between EDNY and non-EDNY pro se litigant outcomes after the pro se reform. Non-EDNY in this analysis refers to all New York federal district courts other than EDNY: the Northern District of New York, SDNY, and Western District of New York. The treatment effect is the difference between these two differences—that is, the difference in differences. For more discussion of this methodology, see generally Marianne Bertrand, Esther Duflo, and Sendhil Mullainathan, How Much Should We Trust Differences-in-Differences Estimates?, 119 Q J Econ 249 (2004).
Find out what your jurisdiction does. If they don’t have them, it’s worth it to bring your own. If a hearing means anything to you, the money you shell out for a court reporter will pay back in spades. If it’s difficult to pay for a court reporter, try to stretch those hearings out as long as you can. If you’re in a multi-year case, you might have a hearing only 3 times per year anyway. If you find you’re having more and can’t afford it, prioritize them. This also helps you think strategically about your case.
Consolidate questions. Hourly charges are usually divided into parts of an hour, so you may be charged for more time than you actually spend. For example, if your legal coach bills in 15-minute intervals and you only talk for five minutes, you may still be charged for the whole 15. If that is your coach’s practice, it pays to gather your questions and ask them all at once, rather than calling every time you have a question.

Attorney Bonanno's answers to questions are for general purposes only and do not establish an attorney-client relationship. You should carefully consider advice from an attorney hired and who has all facts necessary to properly advise a client, which is why these answers to questions are for general purposes only and do not establish an attorney-client relationship.

Or at least R.I.P. for non-lawyer pro se litigants. Just when you thought the Supreme Court season had finally come to a close, the Court released a new rule book this morning. It’s 80 pages long and mostly a rehash, but the addition of Rule 28.8 garnered some attention for finally closing a door on the practice of non-lawyers arguing before the Court.
116. A difference-in-differences analysis is an analysis that looks at two samples (here, EDNY pro se litigant outcomes and non-EDNY pro se litigant outcomes) and compares the difference in the average result between those two groups before and after a treatment. This analysis compares the difference between EDNY and non-EDNY pro se litigant outcomes before the pro se reform with the difference between EDNY and non-EDNY pro se litigant outcomes after the pro se reform. Non-EDNY in this analysis refers to all New York federal district courts other than EDNY: the Northern District of New York, SDNY, and Western District of New York. The treatment effect is the difference between these two differences—that is, the difference in differences. For more discussion of this methodology, see generally Marianne Bertrand, Esther Duflo, and Sendhil Mullainathan, How Much Should We Trust Differences-in-Differences Estimates?, 119 Q J Econ 249 (2004).
Commentators have seen Turner as a complete rejection of civil Gideon, effectively foreclosing the possibility of an expanded right to counsel in civil litigation, at least for the foreseeable future.44 However, commentators have also seen the holding in Turner—that due process requires trial courts to protect pro se litigants’ rights via procedural safeguards—as a nod toward a new and potentially more fruitful approach to pro se litigation: reforms in trial courts.45
121. See Bloom and Hershkoff, 16 Notre Dame J L, Ethics & Pub Pol at 493–94 (cited in note 74). About 15 percent of civil cases were pro se cases in 1999, and a substantial percentage of those cases were prisoner pro se cases, so the percent of the docket comprised of nonprisoner pro se cases was relatively close to the typical 9 percent of the federal docket for the time period that Table 2A covers. Further, the bulk of those cases were civil rights cases, employment discrimination cases, and Social Security cases. The former two categories are also the most typical types of nonprisoner pro se litigation in this analysis, as Table 2D shows.

One newspaper report from the time suggests Parker did fine, though it was clear he was an amateur. He arrived with a thick pile of notes, wagged his fingers at the justices, and wore striped pants and a cutaway jacket. That was what all lawyers once wore to argue at the court, but it had fallen out of favor for all but government lawyers by the time Parker appeared before the court.
One more effective path might look toward a growing body of research on more effective ways to provide self-help resources and literature to pro se litigants. A recent article by Professors Greiner, Dalié Jiménez, and Lois R. Lupica details their endeavors to develop a theory of the issues that potential pro se civil litigants would face in the legal process. Their article then draws on recent developments in a number of fields, such as education, psychology, and public health, to imagine what truly effective self-help materials would look like and how they might help pro se litigants fare better at trial.132 Courts and commentators could try to enhance the effectiveness of their reform efforts by drawing on this and other similar research. Using this kind of research to provide effective educational handbooks or to help courts communicate in ways that are more useful to pro se litigants could enhance the types of pro se reforms analyzed in this Comment.
The SDNY, which provides the funding for the clinic, recently approved the introduction of a mediation project, which in a short period of time has proved to be highly effective. Clinic staff members and volunteers are now permitted to represent pro se litigants in connection with settlements.  Litigants get an impartial view of the strengths and weaknesses of their cases, resulting in earlier resolutions. Over half of the litigants who were represented by clinic staff members or volunteers settled their cases.
According to Boston Bar Association Task Force 1998 report in every court studied by the task force, litigants without lawyers are present in surprising numbers. In some counties, over 75% of the cases in Probate and Family Courts have at least one party unrepresented. In the Northeast Housing Court, over 50% of the landlords and 92% of the tenants appear without lawyers in summary process cases.[40]
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