Plaintiff Trial Lawyer Tips

FEBRUARY 3, 2025

To do so, they will construct their understanding of the case as the story unfolds. I present my cases as important cases in which the jury has the opportunity to make a difference for the better. I will spend time on each element of damage in the jury instruction. Tell the story in the present tense as it is happening.

Cross-Examination 100

Cross-Examination Opening Statement Jury Selection Evidence 100

Next Generation E-Discovery Law & Tech Blog

SEPTEMBER 11, 2024

In its first eDiscovery failing, Arch Insurance did not issue a litigation hold until four years after having constructive notice of the claim. The Court ruled that the Plaintiff could introduce evidence of Arch Insurance’s eDiscovery failures at trial and would issue a jury instruction as an evidentiary sanction.

Insurance 59

Insurance Jury Instructions Evidence Discovery 59

Joshua Gilliland

DECEMBER 10, 2015

Determining the case story lawyers want to tell the jury focuses review to find that information. Moreover, jury instructions are highly effective in structuring document review to find what is relevant. Bow Tie Thoughts Relevancy review does not require eyes on every document.

Discovery 52

Discovery Jury Instructions Trial Preparation Construction 52

Sound Jury Blog

JANUARY 8, 2024

motions in limine), but even some of those should be thought of as squirrels since they distract you from your carefully constructed litigation plan. And 3) How do you want jurors to apply the jury instructions to the verdict form questions? Yes, there are “squirrels” that are not as trivial (e.g.,

Litigation 52

Litigation Jury Selection Closing Argument Depositions 52

Jury Analyst

AUGUST 7, 2024

Confirmation bias explains why it often feels futile to argue politics with someone with a different viewpoint; you can construct the best argument in the world, and it wont override a persons drive to maintain their beliefs.

Jury Selection 40

Jury Selection Voir Dire Litigation Evidence 40