I thought I would share a series of brief basic thoughts about communication generally. I am going to start with a note about jury selection fundamentals and communication:

In voir dire follow the practice of not allowing yourself to say anything at the end of a juror’s response until you have taken a full breath in and out. You will find that this will result in correct timing and will actually move things more quickly in the long run. The primary rule is that they talk the most and you talk the least.

The first rule is: Don’t interrupt the juror. Look at the juror and not your notes while the juror is talking. Acknowledge you heard what was said. Think of yourself as a referee whose job it is keep the game moving without controlling it. To keep it moving do not correct, criticize or gloat.

Remember, no matter how a person may revise an answer under questioning, their original answer, when asked by the judge or other attorney or to you, is probably their true belief. Keep in mind, if you want someone to reveal something about themselves it is essential you first reveal something about yourself.

In general, the three key characteristics that provide consistently reliable information about a prospective juror are these:

(1) Capacity for compassion: "What’s in it for me? vs loving concern" Ask about volunteer or charity work, pets, relationship to family or parents.

(2) Socioeconomic background: "How was this person raised?"

(3) Satisfaction with life: "How do you like your job? If you could change your life what would you do?"