UTBMS Code L430 — Trial Briefs/Motions
Preparation of trial briefs, motions in limine, proposed jury instructions, verdict forms, and other trial-related filings that must be submitted before or during trial.
schedule When This Code Is Used
When the trial team is preparing pre-trial filings including trial briefs, motions in limine to exclude evidence, proposed jury instructions, special verdict forms, and any motions that must be resolved before trial begins.
warning Common Billing Violations
Billing for motions in limine on issues that were already briefed as discovery motions under L350, effectively double-billing the same legal argument
Excessive jury instruction research and drafting hours when standard pattern instructions are available
Over-staffing trial brief preparation with redundant attorney roles
Billing for trial briefs that substantially recycle content from earlier summary judgment briefs without meaningful new analysis
timer Typical Hours
Trial brief: 20-50 hours. Set of motions in limine: 20-60 hours. Jury instructions: 10-25 hours. Verdict forms: 3-8 hours.
flag Red Flags to Watch For
Jury instruction hours exceeding 25 when pattern instructions cover most of the relevant law
Motions in limine that restate arguments already made in discovery motions under L350
Trial brief content that substantially duplicates summary judgment briefing under L240
More than three attorneys billing for jury instruction preparation
check_circle Best Practices for Review
Compare trial brief content against earlier motion briefs to identify and reject duplicative work
Require use of pattern jury instructions where available, limiting custom drafting to novel legal issues
Set separate budgets for each trial filing category: trial briefs, motions in limine, jury instructions
Establish that verdict form preparation is associate-level work with one round of partner review
link Related Codes
analytics Key Statistics
Motions in limine are filed in 85% of federal civil trials, with an average of 4-8 motions per trial
Source: Federal Judicial Center, 2023
Trial brief and motion preparation accounts for 5-10% of total litigation costs in cases that proceed to trial
Source: Thomson Reuters Legal Department Benchmarking Report, 2024
Frequently Asked Questions
What does UTBMS code L430 cover for trial briefs and motions? expand_more
UTBMS code L430 covers preparation of trial briefs, motions in limine, proposed jury instructions, verdict forms, and other trial-related filings. It addresses the written advocacy work that frames trial issues and seeks to exclude or admit evidence.
How do you control costs for trial briefs under L430? expand_more
Set per-brief budget expectations and require advance approval for the number and scope of motions in limine. Ensure research from earlier phases (L120, L240) is leveraged rather than re-conducted. Limit revision cycles and require use of templates for routine filings.
What billing violations occur under UTBMS code L430? expand_more
Violations include re-researching legal issues already addressed in earlier motions, excessive revision cycles on routine trial filings, billing partner rates for drafting proposed jury instructions that are largely standardized, and block billing trial brief work with other trial preparation tasks.