Appeals & Critical Motions

Strategic Advocacy when The Outcome Matters Most

At O’Connell & Aronowitz, our Appeals & Critical Motions practice provides focused, high-level advocacy for clients and trial teams facing the most consequential stages of litigation.

Some matters require full appellate representation after a judgment, order, or agency determination. Others require appellate-level analysis before the case reaches that stage—when a dispositive motion, preservation issue, stay application, or strategic trial-court ruling may shape the outcome of the litigation. Our team is equipped to assist in both settings.

We bring disciplined legal analysis, persuasive writing, and strategic judgment to matters where the law is complex, the record matters, and the stakes are high.

Appellate Services

Our appellate practice helps clients pursue, defend, and preserve important outcomes in New York and federal appellate courts. We are prepared to step in after a favorable result to protect a hard-won victory, after an adverse ruling to evaluate and pursue appellate options, or earlier in the case to help preserve issues for review.

We provide a full range of appellate services, including:

• Appeals as of right
• Motions for leave to appeal
• Interlocutory appeals
• Motions for stays pending appeal
• Administrative agency appeals
• Amicus curiae briefs
• Appellate issue evaluation
• Oral argument preparation and moot courts

We assist clients and trial teams with identifying appealable issues, evaluating standards of review, developing appellate strategy, researching and framing legal arguments, preparing persuasive briefs, and presenting the case effectively at oral argument.

With decades of combined experience in New York and federal appellate courts, our attorneys understand that successful appellate advocacy requires more than strong writing. It requires careful issue selection, command of the record, attention to preservation, strategic use of procedure, and a clear understanding of what appellate courts are most likely to find persuasive.

Critical Motions Assistance

Not every case-defining issue arises after judgment. Many of the most important litigation decisions occur in the trial court, long before an appeal is filed. Our Critical Motions practice provides appellate-level support at those decisive moments.

We assist clients and trial counsel with complex legal issues, high-stakes motions, preservation strategy, and record development. Our role may be public-facing as co-counsel or limited to behind-the-scenes consultation, depending on the needs of the case and the client relationship.

Our critical motions assistance includes:

• Dispositive motions
• “Bet-the-company” and high-stakes motion practice
• Emergency applications and stay strategy
• Motions for reargument, renewal, reconsideration, or vacatur
• Issue preservation and record development
• Complex substantive and procedural research, analysis, and argument development

This work is especially valuable when a case presents unsettled law, a difficult procedural posture, a potentially dispositive legal issue, or a ruling likely to become the focus of appellate review. By bringing appellate perspective to the trial court, we help strengthen arguments, preserve issues, and position the case for the next stage of litigation.

Elite training. Practical results.

Our practice is strengthened by attorneys with top-tier academic credentials, including Harvard Law and MIT training, combined with real-world experience handling high-stakes commercial, public law, institutional, and individual matters.

We bring clarity to complex legal issues and focus on what courts are most likely to find persuasive: a strong record, a sound legal theory, precise issue framing, and clear, credible advocacy.

A Generalist Practice with Broad Depth

O’Connell & Aronowitz maintains a generalist appellate and critical motions practice with experience across a wide range of industries and legal issues, including:

• Commercial and business disputes
• State and federal constitutional matters
• Civil rights and civil liberties claims
• Administrative agency appeals
• Insurance coverage disputes
• Personal injury matters
• Criminal defense

Because appellate and case-defining legal issues arise across subject areas, our practice is built to master the record, understand the governing law, and present the strongest possible argument in the forum that matters.

Co-Counsel and Referral Partnerships

We work alongside trial counsel to strengthen appeals, preserve key issues, and support critical motions without disrupting existing client relationships. Our team offers flexible co-counsel and referral partnerships for both appellate matters and trial-court critical motions work.

We can provide full representation, serve as co-counsel, or assist behind the scenes with targeted research, drafting, strategy, and argument preparation. Whether the matter calls for a complete appellate engagement or focused assistance at a critical point in the litigation, we integrate seamlessly with clients, trial teams, and referring counsel.

Focused Advocacy for Complex, High-Stakes Matters

When the Law Is Complex and The Stakes Are High, Strategy Must Be Intentional. O’connell & Aronowitz Provides the Focused Advocacy, Precision Writing, and Courtroom Readiness Required for Appeals, Critical Motions, and Case-Defining Legal Issues.

If you have a case with appellate potential, a significant motion, or a complex legal issue that may shape the course of litigation, please contact our Appeals & Critical Motions team to discuss how we may assist.