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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
Damage opening statement outline

Damage opening statement outline

I’ve talked about one page notes during trial in several different context’s. The idea of a one page reminder is tokeep one focused on thekey issues, to force simplification and to provide notes for reference that are easily used. This is a one page outline of an opening statement in ajury trial involving a badly injured man. This portion is the damage portion only. The case involved a manelectrocuted while working resulting in severe burns and multiple traumatic amputations. I…

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Always stay focused on the key issues – don’t chase defense rabbits

Always stay focused on the key issues – don’t chase defense rabbits

When we are ready to start a trial we often have confusion about whatissues to spend time on.As the case progressed thorough discovery we learned of more and more issues. There were damage facts we didn’t know about that thedefense nowhas seized upon. Defense experts have raised issues in our discovery that we hadn’t anticipated.As these issues develop we have run about trying to find answers and plug the holes in the dike. Now that the trial is around the…

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“keep it simple”isn’t just some meaningless slogan

“keep it simple”isn’t just some meaningless slogan

In 2006 a Princeton psychologist published an paper involving a study he conducted regarding simplicity of words used. The article Consequence of Erudite Vernacular Utilized Irrespective of Necessity reported on the use of complicated language and big words as to the impression formed by the person reading them. His study concluded that people whouse big words and complicated language simple words would be sufficient are seen as less intelligent then those who use a more basic vocabulary. It turned out…

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