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

Plaintiff Trial Lawyer Tips

Since the publication the defense bar has concentrated on how to prevent and object to use of this approach. An effective opening statement leaves the jury with nothing on their mind except what the defendant did. Less is more in making an openings statement. No advocacy. No useless medical terms.

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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. See: Washington Pattern Jury Instruction 21.01 See: Washington Pattern Jury Instruction 21.01