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Month: December 2013

OPENING STATEMENT ON DAMAGE PORTION OF CASE

OPENING STATEMENT ON DAMAGE PORTION OF CASE

  For a description of this trial see I thought I’d share the short opening statement I made which was limited to the damage portion of the case since my partners had covered liability before I spoke. I don’t offer this as a model, but simply to suggest that one can achieve multimillion dollar verdicts in major injury cases without a lengthy opening statement on damages. What isn’t illustrated are the slides that accompanied this opening and which allowed me…

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SEMINAR THOUGHTS

SEMINAR THOUGHTS

I just got back from New York where I spoke at an AAJ seminar. There were excellent speakers on Friday which I missed because of my having to travel that day. On Saturday Mark Mandell from RI, Russ Herman from LA and Tom Girardi from CA spoke ahead of me. I was the last speaker. Here are some random ideas I noted from the speakers. The importance of the “the rule of three.” List things in three’s – it’s powerful….

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CROSS EXAMINATION REGARDING NOTICE TO MANUFACTURER

CROSS EXAMINATION REGARDING NOTICE TO MANUFACTURER

One expert I started to prepare cross examination for in my most recent case was never called. She was to testify that the reported cases to the company about patient airway fires weren’t enough to require the manufacturer to do anything and that the instructions provided with the tube were adequate to advise the doctors (who never bothered to read them). I wanted to show the doctors were also negligent for not reading the instructions. In anticipation of this defense witness  I…

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