Discovery, Jury Selection 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

Causation should be talked about in jury selection. Consider using the David Ball technique of providing ideas in jury selection. Remind the jury in jury selection, opening statement, witness testimony and in final argument the law only requires proof that something is more likely than not.

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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