Lack of preservation is the bane of the appellate lawyer's existence.
The first sentence of every argument on appeal must indicate whether the
issue is preserved and how it is preserved. This can set the tone
for the entire argument. If an issue is unpreserved, an appellate
court will only examine it if the error is such that there is a substantial
possibility that the result of the trial would have been different absent
the error. These charts are a rough guide to the steps that should
be followed when preserving an evidentiary error - John Palombi,
Appellate Brach Manager
