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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
A direct examination outline of a treating doctor

A direct examination outline of a treating doctor

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I’ve written before about my belief that your trial notebook (and deposition notebook) should contain basic check lists or outlines for every examination you conduct whether you are an experienced or inexperienced trial lawyer. All of my outlines are very simple and basic. For each examination I revise them to fit the particular situation involved. I use them as a reminder list to be sure I cover each point I need to cover. I never read from them, but rather…

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Using notebooks for organizing your trial material

Using notebooks for organizing your trial material

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For many years of trial work I have used notebooks as my primary organizational tool for trials.Originally I used schoolthree ring notebooks withdividers and lined paper. My trials were not very long nor complicated and this was how I organizedmy trials. As trialsbecame more involved I began to add three ringwitness materials notebooksorganized alphabetically. This notebook was used along with expansion files with thewitness deposition, statements and resource materialcoded to the notebook.I could pull the deposition, exhibits and materials out…

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Direct examination of plaintiff expert economist

Direct examination of plaintiff expert economist

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I like to have in my notebook outlines for the direct examination of witnesses. For many experts a standard outline can be created that you can use from case to case by using it as a checklist of matters to be sure to cover. They don’t have to be complicated, just complete. Here’s one that is intended for use with your expert economist. A.QUALIFICATIONS1. Name & address2. Profession3. Present employment4. Formal education(1) degrees obtaineda. whenb. where5. Publications6. Professional societies7. Professional honors…

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