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Author: Paul Luvera

Luvera practiced plaintiff law 55 years. He is past President of the Inner Circle of Advocates & Washington State Trial Lawyers Association. Member ABOTA, American College of Trial Lawyers, International Academy, International Society of Barristers and the American Trial Lawyers Hall of Fame. Book Luvera on Advocacy available at Trial Guides Publishing Email paul@luvera.org
NEURO LINQUISTIC PROGRAMING & PERSUASION THROUGH EMBEDDED COMMANDS

NEURO LINQUISTIC PROGRAMING & PERSUASION THROUGH EMBEDDED COMMANDS

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The book with the interesting title Unfair Secrets of Hypnotic Selling with NLP  was written under the pseudonym  Franz Anton Mesmer II. In spite of the implications of the title, this book has very helpful information about techniques of NLP regarding presenting information in a powerful manner.  For our purposes it is important to understand concepts of “light trance” and “embedded commands” as well as framing issues and negotiation ideas which the book discusses. The author also discusses NLP concepts of…

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DEPOSITION OF DEFENSE HIRED SURVIELLANCE INVESTIGATOR

DEPOSITION OF DEFENSE HIRED SURVIELLANCE INVESTIGATOR

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I recently deposed an investigator hired by the defense who kept my client under surveillance over a long period of time. While you may not have had this happen to your client you may find the outline helpful. EXAMINATION OF INVESTIGATOR (“tailing, stakeout, spying, tracking, snooping, secretly watching, sneak, peeping Tom, prying, invading privacy”) INTRODUCTION 1.NAME (only – not address -save for later) WHAT HE DID GENERALLY  IS IT TRUE STARTING IN MARCH OF 2011 YOU BEGAN SECRETLY WATCHING THE…

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DIRECT EXAMINATION OF ECONOMIST

DIRECT EXAMINATION OF ECONOMIST

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I am scheduled to start a trial in a week involving a man who was injured while working. Our economist is scheduled to deliver a baby when the trial is going on  so I  needed to perpetuate her testimony. Here is the simple outline I prepared for her perpetuation deposition. We had discussed this before I used it so she knew the areas I wanted her to cover by these questions. This outline assumes the economist can explain fully the…

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