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- SOME RANDOM THOUGHTS ABOUT ARGUING TO THE JURY
- ALWAYS APPEAL TO THE JURORS NEED FOR A JUST OUTCOME THROUGH A COMPELLING STORY
- POLITICAL WISDOM FOR TRIAL LAWYERS
- DAVID BALL TRIAL CONCEPTS
- WHAT PUPPETS CAN TEACH TRIAL LAWYERS ABOUT PERSUASION
- THE TOOL OF PSYCHODRAMA FOR PLAINTIFF ATTORNEYS
- JUST BECAUSE YOU KNOW THE LYRICS DOESN’T MEAN YOU CAN SING
- UNDERSTANDING WHY JURORS WANT TO BLAME THE INJURED PLAINTIFF
- MISCELLANEOUS IDEAS REGARDING MEDICAL MALPRACTICE CASES
- PREPARE IN ADVANCE FOR NEW CLIENT CONFERENCES WITH A CHECKLIST
- SOME MAGIC WORDS & PHRASES FOR PERSUASION
- DEATH EXPRESSED BY SONG, POEM AND LITERATURE
- GENERAL ADVICE TO RETAINED EXPERT ABOUT TESTIFYING
- SHOULD YOU TELL THE JURY IN VOIR DIRE HOW MUCH YOU WANT IN THEIR VERDICT?
- A CHECKLIST FOR A RETAINED EXPERT WITNESS
- A GREAT TRIAL LAWYER IS SOMEONE WHO IS ALSO A GREAT LISTENER
- FIGHTING BACK AGAINST ADVERSITY AND FAILURE
- EVALUATING OUR PROCEDURES FOR DETERMINING JUROR IMPARTIALITY
Category Archives: Discovery
DEPOSITION OF DEFENSE HIRED SURVIELLANCE INVESTIGATOR
I recently deposed an investigator hired by the defense who kept my client under surveillance over a long period of time. While you may not have had this happen to your client you may find the outline helpful. EXAMINATION OF … Continue reading
Posted in Discovery, Uncategorized
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INTERROGATORIES ASKING FOR INSURANCE COVERAGE INFORMATION
Does your state discovery rules allow you to ask the defendant about insurance coverage? If so, you should always take advantage of that right. Insist upon complete answers and don’t be satisfied with answers like “adequate insurance exists.” If allowed … Continue reading
Impeachment on revising deposition testimony
I’d like to share an e-mail discussion among some plaintiff lawyers regarding the followingquestion: What do you all do when you get back the deposition corrections sheet from the defendant and find many "yes"s are changed to "no"s and visa … Continue reading
Posted in Discovery
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