Can a motion for a directed verdict be made at the close of all of the evidence?

Even before the 2006 amendment, there was one recognized exception to the requirement for a Rule 50(a) motion at the close of all of the evidence - namely, where an earlier motion for a directed verdict has been taken under advisement by the trial judge. The trial court's reservation of a ruling on a motion for a directed verdict made before the close of all the evidence maintains the motion as a continuing objection to the sufficiency of the evidence, provides notice to the opposing party of the challenge, and constitutes a judicial indication that renewal of the motion is not necessary to preserve the moving party's rights. See, e.g., Ebker v. Tan Jay International, Ltd., 739 F.2d 812, 823

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