Read The Rules. Know The Rules. Start with Tenn. R. Civ. P. 54.02
When I first started practicing law, my mentor was a procedure savant. He knew the Rules of Procedure inside and out. In turn, I eventually learned the Rules.
That's my single biggest piece of advice for any litigation attorney: Know the Rules of Procedure. If you're in state court, read the Tennessee Rules of Civil Procedure. Before you go to court, read that County's Local Rules. The key to success at anything is knowing the rules. Sports. Checkers. The practice of law. A strong, working knowledge of the rules of procedure puts you ahead of 85% of your fellow lawyers.
Recently, while reading a new Tennessee Court of Appeals opinion about final judgments and appeals, I was reminded of a lesson my old boss taught me about Tenn. R. Civ. P. 54.02.
Rule 54.02 applies in cases where are multiple parties and multiple claims for relief, but a party is able to resolve its claims as to part of the litigation. In that circumstance, Rule 54.02 allows the trial court deem the judgment as to that part of the case "final," which means that the party's appeal deadlines start to run and, more importantly, the plaintiff can proceed with collection on the judgment as to that party.
But, you don't get Rule 54.02 relief unless you think to ask for it. Under the Rule, you have to (1) specifically request that the judgment be "final" and (2) use magic language by which the Court makes an "express determination that there is no just reason for delay" and an "express direction for the entry of judgment."
The new case I cite above is interesting, because the Judgment that was appealed included the Rule 54.02 magic language, but the Court of Appeals denied the appeal as premature, because there was still one loose end (the assessment of attorney fees). It's interesting (and re-assuring) to see the appellate court look at substance over form.
Even though Rule 54.02 led this attorney astray, don't forget to include that text in your Judgments. It's most powerful when you have the chance to take a judgment against one liable party early in the case, but one of the other defendants shows up and contests his own liability. In that scenario, while you're litigating the matter against one defendant, you can commence execution and collections on the other, without waiting until getting all the claims resolved.