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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
MEMO RE DISCOVERY ABOUT SURVEILLANCE

MEMO RE DISCOVERY ABOUT SURVEILLANCE

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                               I have had the issue of the defense or insurance company hiring someone to spy on my client in the hopes it will show the client is not hurt as badly as claimed. What follows is the raw memo I developed in anticipation of creating a deposition outline. You hopefully may create ideas from it if you have the issue. (FRAME AS: “tailing, stakeout, spying, tracking, snooping, secretly watching, sneak, peeping Tom, prying, invading privacy”) INTRODUCTION . 1.Name,…

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WHAT YOU SHOULD KNOW ABOUT THE IMPACT OF DEATH OF A LOVED ONE

WHAT YOU SHOULD KNOW ABOUT THE IMPACT OF DEATH OF A LOVED ONE

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Trial lawyers represent people who have lost a loved one as a result of some negligent act. While they are familiar with the analysis and preparation of the liability case, the damage case may be a challenge for them. In order to present the damage consequence of a wrongful death case, the lawyer needs to understand what the client is going through. Psychodrama is a helpful way to do this when properly conducted. Here is a brief outline of some…

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RANDOM THOUGHTS ABOUT BEING A BETTER TRIAL LAWYER

RANDOM THOUGHTS ABOUT BEING A BETTER TRIAL LAWYER

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`Here are a collection of ideas and thoughts from a variety of sources about being a trial lawyer. From the importance of being an authentic person to general concepts, this collection of brief ideas contains many of the essentials for help in developing better trial skills. They may seem simplistic and obvious, but take the time to inventory against your own trial conduct to see if improvement is needed. . . AUTHENTICITY . 1.Margery Williams “The Velveteen Rabbit” . “Real…

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