Plaintiff Trial Lawyer Tips

BASIC OUTLINE LOSS OF CONSORTIUM CLAIM

May 14, 2026 Paul Luvera Comments 0 Comment

LOSS OF CONSORTIUM CLAIM WPI 32.04 Measure of Damages—Loss of Consortium—Spouse/State Registered Domestic Partner Loss [to the plaintiff husband] [to the plaintiff wife] [to the plaintiff state registered domestic partner] of the consortium of [his] [her] [wife] [husband] [state registered domestic partner].The term “consortium” means the fellowship of [spouses] [husband and wife] [state registered domestic partners] and the right of [one spouse] [one domestic partner] to the company, cooperation, and aid of the other in the [matrimonial] [domestic partnership] relationship….

LEAVING THE COURTROOM: REFLECTIONS OF A PLAINTIFF TRIAL LAWYER

April 22, 2026 Paul Luvera Comments 1 comment

Introduction The world has turned many times since I took the oath to become a lawyer in 1959. That year, the minimum wage was $1, gasoline cost $.25 gallon, and a loaf of bread was $.20. My law school graduation was in a movie theater in downtown Spokane. All of us graduating had attended night law school at Gonzaga from 7:00 pm to 10:00 pm Monday through Friday for the past four years. Most of us had jobs during the…

THE GERRY SPENCE DEPOSITION APPROACH

April 8, 2026 Paul Luvera Comments 1 comment

Gerry Spence advised an approach to taking the deposition of a fact witness (non-expert) that emphasized conversational inquiry rather than confrontational questioning. His approach was to have a demeanor that was calm and non-threatening with the witness. In practice, a Spence deposition was much more like a conversation than an interrogation. That relaxed demeanor influenced the witness to say far more than they planned. He argued “The deposition is not the place to win the case.” He recommended that lawyers…