Remove Jury Instructions Remove Opening Statement Remove Witnesses
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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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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

by this witness). The opening should give the jurors a vision of the completed building, but also the “work flowchart” for how they will get there. Then, with each witness, remind jurors what “work” is being done through constant sign-posting, which is essentially juror handholding, which is critical.