Do you tell the jury how much you want at the start of the trial or wait for argument?

# Do you tell the jury how much you want at the start of the trial or wait for argument?

Recently there was an email discussion among good plaintiff lawyer about whether you tell the jury how much you are asking in jury selection or wait until final argument. Some cited David Ball and said they tell the jury how much they are asking for and some said they are concerned about doing that. Here was my response.

In good liability cases with major damages I agree with Spence’s approach to start out in jury selection with a number, but that may be something other then a specific number For example "if after you’ve heard all the evidence, listened to the law and are convinced in the jury room a reasonable and fair verdict is more then $18 million dollars would you sign the verdict?" For example "if after you’ve heard all the evidence, listened to the law and are convinced in the jury room a reasonable and fair verdict is more then$18 million dollars would you sign the verdict?" You’d be surprised how often jurors are excused for cause on such a question. Or in a rare case I might say "At the end of this case after you have heard all the evidence and the law, we will suggest to you a reasonable and fair verdict is \$40 million dollars? If you ageed that that was a reasonable and fair verdict would you sign a vedict for tha amount?