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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
BASIC OUTLINE FOR PERSONAL INJURY SUMMATION

BASIC OUTLINE FOR PERSONAL INJURY SUMMATION

There are a many approaches to the structure of a final argument in an injury case. One reliable approach is to base it on the jury instructions. Using the jury instructions as the foundation for argument gives it the authority of law from the judge. Here is one example of a very simple outline from a Washington state jury trial.  . 1.THE VERDICT FORM . (1)Put verdict form on screen (2)Go through each question & explain significance (without giving verdict…

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BASIC OUTLINE FOR DIRECT EXAMINATION OF PLAINTIFF ECONOMIST

BASIC OUTLINE FOR DIRECT EXAMINATION OF PLAINTIFF ECONOMIST

“I’m not an economist and we all know economists were created to make weather forecasters look good.” Robert Murdoch In cases with significant economic loss, we decide that we need an expert in economics to project the future economic loss for the jury. It is not error to refuse to instruct the jury to discount future medical expenses and lost earning capacity to present cash value if no evidence is introduced as to the proper interest rate or mathematical formula….

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CLEAR COMMUNICATION IN A TIME OF PANDEMIC & POLITICS

CLEAR COMMUNICATION IN A TIME OF PANDEMIC & POLITICS

Trial lawyers should always strive for clear and understandable communications when dealing with juries. However, we are now in a crisis involving politics and medical pandemic. During periods of crises like this, people are distracted by the fears and challenges created. They have trouble processing information. That is due to the large amount of communications they receive about these problems on a frequent basis. We trial lawyers should keep this in mind regarding our trial presentations. We need to be…

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