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Here is an example of the use of “rules” in a recommended “Reptile” approach for openingstatement: PLAINTIFF OPENINGSTATEMENT 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.
The reality is that a jury, following the juryinstructions can find significant negligent conduct they object to, but conclude it did not cause the harm plaintiff is complaining about. See: Washington Pattern JuryInstruction 21.01 See: Washington Pattern JuryInstruction 21.01 It could be scales.
Openingstatement, 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.
Eighty percent of the talking should be by the jury. OpeningStatement. There are many ways to approach the story you are going to tell in the openingstatement. It is always better to use visual aids during the openingstatement which will help shorten, simplify and help understanding by the jury.
One of the most frustrating aspects of trial for the jury is that they are not given the juryinstructions 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-openingstatements.
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