Discovery, Jury Instructions and Opening Statement

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

Plaintiff Trial Lawyer Tips

NOVEMBER 17, 2024

The reality is that a jury, following the jury instructions can find significant negligent conduct they object to, but conclude it did not cause the harm plaintiff is complaining about. See: Washington Pattern Jury Instruction 21.01 See: Washington Pattern Jury Instruction 21.01 It could be scales.

Burden Of Proof

Burden Of Proof Jury Instructions Jury Selection Evidence

CONSIDER A TRIAL CHECKLIST

Plaintiff Trial Lawyer Tips

OCTOBER 31, 2024

THREE PRIMARY DEFENSE CLAIMS __ __ __ PLAINTIFF PROOF OF CAUSATION __ DEFENDANT CAUSATION DEFENSE _ PRELIMINARY STATUS REVIEW  Review local rules regarding deadlines and requirements DISCOVERY REVIEW Interrogatories  Review defendant’s answers to interrogatories. Note incomplete answers for motion. Decide how to use at trial.

Cross-Examination

Cross-Examination Exhibits Opening Statement Interrogatories

Trial Strategy Today

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

CONSIDER A TRIAL CHECKLIST

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