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Prepare Your Witness Virtually: Seven Best Practices

As we are moving up yet another hill on the pandemic case-count rollercoaster, hopefully the last rise before the final descent into a vaccine landing zone, courts are once again pulling back in–person trials, while lawyers...more

Transition With Meaning: Nine Ways to Avoid “My Next Point Is…”

All the way back to my days as a public speaking professor and debate coach, I stressed the practical importance of a transition. The goal, I emphasized, is not just the formal nicety of appearing organized, but is rather to...more

Follow Judge Simon’s ‘Casa Le Pyro’

Looking at the question, “What does a federal judge expect from an Assistant United States Attorney (AUSA)?” U.S. District Court Judge Michael H. Simon of the District of Oregon, in a recent issue of the DOJ Journal of...more

Account for One Reason the Polls Are Broken: Social Alienation

We all know by now there were errors in the pre-election polls. While Joe Biden still scored a decisive win, there wasn’t the dramatic margin that many polls predicted. Part of the problem is that the task of sampling the...more

Be Thankful (Jurors Like You Better That Way)

In the current wave of this pandemic year, as many trials and in-person jury research projects are on hold, the social science research has continued. I’m thankful for that, and for this post, I want to appreciate a new study...more

Don’t Be Too Hot for Zoom

When it comes to presentation style in the courtroom, there are definitely times to “bring the fire.” Impassioned rhetoric is best used sparingly, and after you have gained your audience’s trust, but when it fits, powerful...more

Take Some Lessons from “Deep Canvassing”

It is becoming axiomatic that you can’t talk people out of hardened views. Particularly on political subjects; the common view is that we are in a “post-persuasion” era. Perhaps that depressing assumption explains why I was...more

Continue the Conversation

From readers of this blog, I sometimes hear, “I don’t always agree with you, but I always find you worth reading.” That is one of my favorite compliments, because of, and not despite, the disagreement. It wouldn’t be that...more

Make Sure Your Filings Pass the “Straight Face Test” (2020 Election)

Earlier this week, I wrote about winning and losing with dignity. For this post, I want to take a closer look at the potential flip side of that. In the days since the close state elections reached an apparently clear result...more

Win and Lose With Dignity

After a tense few days of states counting votes while the public kept refreshing the CNN map, the 2020 Presidential Election has finally been called. And at least in the initial aftermath, we have seen starkly different...more

Don’t (Fully) Trust Public Opinion Polls

The 2020 election seems to be nearing the end of the vote-counting phase, with the final ballots in Nevada, Arizona, and Pennsylvania being tallied as I write. But one clear loser is already evident: the preelection polls....more

Enjoy the Calm, Prepare for the Storm

On the eve of the final voting day in the 2020 election, it feels like the calm before the storm. As divided as Americans are in these times, there are a few beliefs that everyone seems to share...more

Allow a Little Awkward Silence

Trial lawyers work in words: language that is precise, economical, and influential. Those words are the water that litigators swim in, and for that reason, the absence of words can be a little uncomfortable. That can be an...more

Understand Juror Anxiety

These are stressful times, and there are many reasons to expect that your jury pool in the near future is going to be a little stressed out. In the article, “The Pandemic Juror,” (Wilson 2020) a University of Tennessee law...more

Confront the Reptile in Jury Selection

The Reptile approach of trying plaintiffs’ cases by framing them in terms of personal safety is no longer a new idea. Plaintiffs’ attorneys are also less likely to treat that approach as a cure-all in every trial. But the...more

Address Science Denialism

It has been a tough year for science. On the social-science front, it seems that we have entered a phase where no one believes the polls. To conservative Trump supporters, the consensus of data showing the President well...more

Is It Their Own Fault? Account for ‘General Belief in a Just World’ to Understand Jurors’ View of Blame

So Donald Trump now has the coronavirus. As of press time for this blog post, he is fighting the illness from the Presidential Suite at Walter Reed Medical Center. It is news that struck many as both surprising and...more

Witnesses: Answer Both the Language of the Question and Its Implication

When preparing a witness, there can sometimes be a strong impulse to say, “Just answer the question.” That impulse comes from an appropriate desire to keep things simple, and to keep the witness from wandering or waffling....more

Med-Mal Defendants: You Want a Jury of Educated Legal Skeptics

For trial lawyers, there is a great deal of lore on the kinds of jurors you would want for particular cases. While some attorneys will focus on traits like gender, age, or occupation, the smarter course, in my view, is to...more

Assume Your Potential Jurors Won’t Call Their Bias a “Bias”

Ms. Gray, if you were selected for this jury, do you believe that your experiences or views would bias you in any way against my client?  There is a predictable answer from Ms. Gray: No, I would not be biased, or I feel...more

Comfortably Numb: Account for Desensitization

Recently, I heard about an in-person mock trial during the pandemic conducted by another consultant outside our group. At the beginning of the day, this consultant said, the jurors and the attorneys attending were all pretty...more

Ask Your Online Witness About Their Off-Camera Resources

So you’re conducting a deposition or cross-examination: Where is the witness? Are they right there in the room with you, or are they many miles away in a room with their computer? With the pandemic still raging across the...more

The Reptile Question: Give a Good Answer

“You would agree with me, wouldn’t you doctor, that a physician should never needlessly endanger his patient, right?”  That is a recommended question, probably the main recommended question to plaintiff attorneys who are...more

Note the Stability of Anti-Corporate Bias

Society changes: leaders come and go, the economy goes up and down, wars start and end, and now, medical emergencies arrive and (hopefully soon) depart. But through all of that, for the 12 years we’ve measured it, one thing...more

Voir Dire on Content, Not Effect: Lessons from the Tsarnaev Appeal

We tend to think of “bias” as it applies to juries, but courts can have their own deep-seated practices. For example, judges will often prefer voir dire questions that focus on the juror’s own assessment of the influence of a...more

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