To handle forum non conveniens motions effectively, lawyers should follow a structured, step-by-step approach, starting with a thorough analysis of the case’s connection to the chosen forum and the alternative forum’s adequacy. Preparation should include gathering strong supporting evidence, such as affidavits and expert testimony, to establish the plaintiff’s connection to the forum and address any potential drawbacks of the alternative. Lawyers should also address both private and public interest factors, focusing on convenience, judicial economy, and local interest. Understanding the court’s discretion is crucial, so the argument should be framed not only on legal grounds but also on fairness and access to justice. By anticipating the opposing party’s arguments, presenting a clear, concise case, and building a solid factual record, lawyers can effectively persuade the court to retain jurisdiction.
