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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
 AN OPENING STATEMENT OUTLINE IN A CASE WITH A COMPARATIVE NEGLIGENCE ISSUE

 AN OPENING STATEMENT OUTLINE IN A CASE WITH A COMPARATIVE NEGLIGENCE ISSUE

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      “The most powerful person in the world is the storyteller. The storyteller sets the vision, values and agenda of an entire generation that is to come.” – Steve Jobs . We have cases where the facts or circumstances involve an issue of contributory negligence. In some cases there has been a judicial finding of our client’s negligence or it might involve a tactical decision of ours to concede some percentage of fault on the part of our client or…

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CROSS EXAMINATION OF DEFENSE LIFE EXPECTANCY EXPERT

CROSS EXAMINATION OF DEFENSE LIFE EXPECTANCY EXPERT

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     Here in very rough draft form, is an outline from one of my cases involving a defense expert on life expectancy. Modify and revise it to fit your case situation. The issue of both economic and non economic damage are impacted by this kind of witness  CROSS EXAM DEFENSE LIFE EXPECTANCY EXPERT . A.COLLATERAL ATTACK NOTE: SEE DEPO OUTLINE FIRST . 1.HOW MANY HOURS TO DATE HOW MUCH IS HOURLY RATE 2.TOTAL FEES TO DATE 3.NUMBER OF TIMES TESTIFIED FOR…

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EVASIVE WITNESSES

EVASIVE WITNESSES

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Recently plaintiff’s attorney Rick Friedman shared an article from the defense publication ” For the Defense” published in December 2015 entitled ”Strategies for Responding to Reptile Theory Questions” by John R. Crawford and Benjamin A. Johnson. file:///C:/Users/pnl/AppData/Local/Microsoft/Windows/INetCache/Content.Outlook/EEHZ7017/Strategies-for-Responding-to-Reptile-Theory­Questions-compressed.pdf The article is written in response to David Ball and Don C. Keenan’s book Reptile: The 2009 Manual of the Plaintiff’s Revolution.” The authors summarize the concept in the book as: “In brief, the theory calls for convincing jurors that a defendant’s conduct…

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