Plaintiff Trial Lawyer Tips

The importance of how we frame issues

March 3, 2009 Paul Luvera Comments 0 Comment

I appreciate readers who share ideas and Ronald V. Miller has sent me a link to his website dealing with framing and his use of a George Bush line in arguing for lost wages for his injured client. See Mr. Miller’s website and an explanation at http://www.marylandinjurylawyerblog.com/2009/02/trial_tactic_tips_from_george_w_bush.html Of course, the Rockridge Institute is one of the major websites for information on framing and should be consulted on this subject. http://www.rockridgeinstitute.org/projects/strategic/simple_framing/ Let’s not overlook the infamous Frank Luntz and his Words…

Cross examination of the hired defense medical examiner

February 25, 2009 Paul Luvera Comments 0 Comment

We are often faced with the challenge of examining a physician who has been hired by the defense to examine our client. These witnesses are usually selected because they can be counted on to say the plaintiff isn’t injured or isn’t injured as seriously as claimed. In addition, they are often experienced in testifying and represent a difficult kind of witness to cross examine. Here is a simple basic way to approach these kinds of witnesses. A. BIAS Since you…

Pain – what does it really mean?

February 20, 2009 Paul Luvera Comments 0 Comment

Have you thought what pain really means? When our clients talk about their pain what do we understand about what they are going through? Here are fewbrief ideas about what pain really is: Nazis: when nazis wanted a man to talk they didn’t take his house, or his investment portfolio or confiscate his pension- they took his fingernails Sacrifice anything to avoid pain: We are willing to sacrifice anything to avoid pain. A mother would hock her wedding ring to…