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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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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 It could be scales.

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Getting Back to Basics in Trial Planning

Sound Jury Blog

One of the most frustrating aspects of trial for the jury is that they are not given the jury instructions or know the specific verdict form questions until the end of trial. Therefore, as much as possible, push for a clear statement of the claims and pre-instructions pre-opening statements.