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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
Cross examination about safety

Cross examination about safety

We;ve been in Europe and in fact we leave tomorrow, so I’ve been behind in posting to this site. Here’s a simple outline intended for cross examination about safety. This is from one of my past cases ihvolving an injury at a refinjery. Warning-safety cross examination general outline eliminating or minimizing risk of serious injury or death 1. True that texaco should hold paramount the safety and health of it’s workers?2. Agree with the proposition thatany risk of serious bodily…

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Attacking the expert for bias

Attacking the expert for bias

I feel that the collateral information about an expert which indicates bias is more important in cross examination then the issue involved. If you can show a lack of credibility then the opinions of the expert have little weight with the jury. Here’s a simple check list of reminders to ask at the time of the deposition for you to consider ADVERTISING FOR WORK How became involved in this case Does advertising for work Belongs to expert witness group Any past…

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Some more communication rules to consider

Some more communication rules to consider

Here are some more very basic concepts about good communication. There is nothing profound here, but thoughts that we need to remind ourselves about as it is easy to fall back into "lawyer" thinking and talking. ANSWER THE QUESTIONS THE JURORS ARE ASKING THEMSELVES    Think like a juror. What is it the person in the jury box really wants to know? They want to know the answer to some of these questions they are asking themselves What happened? What does…

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