Remove Evidence Remove Jury Instructions Remove Opening Statement
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USING A “REPTILE” STYLE OPENING STATEMENT

Plaintiff Trial Lawyer Tips

Here is an example of the use of “rules” in a recommended “Reptile” approach for opening statement: PLAINTIFF OPENING STATEMENT OUTLINE “Good morning” (Thats all you say and move on) IDENTIFY THE PRIMARY RULES (No more then three rules) A driver is required to watch the road and see what is to be seen.

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

Plaintiff Trial Lawyer Tips

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. Here are some thoughts about doing that There is a distinct connection of thought between evidence of cause and circumstantial evidence.

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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.

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Getting Back to Basics in Trial Planning

Sound Jury Blog

During mock trials and in trial postmortems, attorneys seem especially angry about jurors “not understanding the case,” “not applying the law,” and/or “ignoring (forgetting) critical evidence.” While it’s likely an obvious list, it’s a list that is often ignored or forgotten – a bit like much of the evidence in trial.