Mini Opening for Voir Dire

jdopening_12384583As they say, never miss a chance to make a good first impression. If the judge permits it, take the opportunity to address prospective jurors before the oral questioning phase of the voir dire has begun. There are many advantages to the mini-opening statement and little downside.  Continue reading

Excusal Remorse: I Want That Witness Back!

witness_78724356Trial attorneys sometimes get excusal remorse, i.e., they excuse a witness and then want to recall that witness back to the stand. Anticipate this reaction and take proaction. Continue reading

5 Steps to Fixing the Facts in Your Client’s Mind

176421487If properly prepared, your testifying client will be relaxed, confident, natural—and a master of pertinent facts. But no one can behave naturally on the stand while trying to keep in mind 50 different facts. When you’re preparing your client to testify, your job is to narrow the case to a few important facts and then fix them in your client’s mind. Continue reading

When a Witness Has Selective Memory

187065476Some witnesses have a crystal clear memory about events unfavorable to your client, but express sweeping memory loss on other contemporaneous events. Here’s how to attack such selective memory. Continue reading

Object with Care During Closing

57280160Attorneys have a lot of latitude in making their closing argument, but there are nonetheless impermissible arguments during closing and thus openings for opposing counsel to object. Even if you’re right, objecting during a closing may not be a smart move. Continue reading

10 Questions for a Client Accused of Shoplifting

139701624When representing a client for shoplifting, don’t take the case lightly; it may seem minor, but it can have major implications. It’s important to get all the facts out during your client interview. Here’s a list of 10 questions to make sure you cover all the bases. Continue reading

Checklist for Preparing Your Witness for Trial

witness_158992082Witness preparation varies from case to case and from witness to witness and there’s no one correct method or simple formula. But there are some things you should always do when preparing a witness for trial. Continue reading

Lineup Your Defense

93951195Your client is arrested and will appear in a lineup. Would you know what to bring and what to do at the lineup? Continue reading

12 Tips for Direct Examination in Depo or at Trial

12Tips-57280162Direct examination is the best way to set the foundation for your case. Here are some tips to help you build that foundation brick by brick.

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Telling the Jury a Compelling Story

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The general rule in organizing statements presented to the jury is the same used by teachers with children: Tell them what you’re going to tell them; tell them; and then tell them what you’ve told them.

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