Remove Burden Of Proof Remove Jury Selection Remove Opening Statement
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    OPENING STATEMENT DAMAGE CONCEPTS

Plaintiff Trial Lawyer Tips

It is important the jury understands there is only one trial to cover the past, present and the future of damages. The jurors need to understand the burden of proof is not “beyond a reasonable doubt” but. The amount of the verdict you are seeking is another subject for opening statement as well as for voir dire.

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DON’T WIN THE BATTLE BUT LOSE THE WAR OVER CAUSATION AS A TRIAL ISSUE

Plaintiff Trial Lawyer Tips

See: Washington Pattern Jury Instruction 21.01 See: Washington Pattern Jury Instruction 21.01 Washington Pattern Jury Instruction 1.03 Causation should be talked about in jury selection. Consider using the David Ball technique of providing ideas in jury selection. It could be scales.

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CONSIDER A TRIAL CHECKLIST

Plaintiff Trial Lawyer Tips

Opening statement, witness examination & summation Depositions  Review all depositions & index for access at trial  Create summary of relevant testimony with index to access at trial  Decide how to use at trial. .  Index & make summary of relevant information for use at trial. Decide how to use at trial.