Most family lawyers do not practice in federal court unless they are working on a Hague Convention case in an international parental abduction. I happened to get involved in one last year because a lawyer-wannabe mother (one of my interstate parental kidnapping cases) filed an action in federal district court to sue everybody involved in state court actions: the family court judge, the court administrator, DHS, protective services worker . . . and more). Good grief, she even got a waiver of fees on an indigency petition. I was relieved that the case was dismissed on summary disposition before I had to show up for a case conference or hearing.
If you practice in federal court, you'll want to review some significant changes to the Federal Rules of Civil Procedure effective on December 1, 2010. Here is a summary of those rule changes:
Some of the key changes:
Specifies affirmative defenses that must be raised in the answer;
Documents prepared in anticipation of litigation by a party or its representative "including the other party's attorney, consultant, surety, indemnitor, insurer or agent" are generally not discoverable
Drafts of expert witness reports and communications between expert and lawyer are generally not discoverable (exceptions: rate charged by expert; facts provided by counsel; assumptions provided by counsel)
In cases where the expert is not required to give a report (e.g., a treating doctor, so-called "lay experts", etc), the party must provide a summary of the facts and opinions to which the witness is expected to testify.
Summary judgment must be supported by pinpoint citation to the record (I may be overstating that a little, but that's the general intent).
A court can deny summary judgment but determine that certain facts or issues are uncontested and thus rule that they are proven and need not be proven again at trial. (This could greatly simplify trial and could give you a means of eliminating the need to bring in a witness on a single point -- and possibly help you in situations where a witness might be unavailable at trial).
The court "should state on the record the reasons for granting or denying the motion."
Affidavits/declarations in support/opposition to SJ must show that the declarant is competent to testify on the matters stated.
Affidavits/declarations submitted in bad faith or solely for delay are sanctionable.
Summary judgment may not be filed more than 30 days after the close of all discovery unless local rule or court order sets a different schedule.
Amendments can be seen here
Excerpt from the judicial conference report explaining the changes here
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