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Reduce Resistance, Tell Stories

In legal settings, the emphasis is often on the positive act of giving arguments and evidence for a given outcome: Share the proof and the reasons to believe, and let those appeals work their magic on your audience. But there...more

Build Trust

At this point, coronavirus precautions in America seem to be on the honor system. With the CDC’s new guidance last week indicating that fully vaccinated Americans could go without masking or distancing in most indoor and...more

When You Contradict Someone’s Bias, Don’t Expect a Backfire (But Don’t Expect Easy Persuasion Either)

Wyoming Representative Liz Cheney has just been stripped of her leadership role as the number three Republican in the House. The precipitating incident seems to be that she would not silence her claim that the 2020...more

The Distributed Courtroom: Don’t Assume the Trial Feels Any Less ‘Real’ When It Appears on Screens

With the extended pandemic restrictions and the resulting court backlogs across the country, we have moved tentatively into the world of online trials and hearings, with participants joining from different locations. In that...more

Witnesses, Add to Your ‘Truthiness’ by Showing Pictures

The idea is a merger of pop culture with academics. In pop culture, “truthiness” refers facetiously to the feeling of something being true, independent of its actual truth value (a term coined by late-night comedian, Stephen...more

Direct Examination: Start With a Goal, Not an Outline

A few years ago, I had the opportunity to attend every day of a civil trial, and then interview all of the jurors at the end of their service. I planned out a very comprehensive interview for each of them, including running...more

Ask Your Factfinders to Participate in Their Own Persuasion

To many trial-watchers, a key moment in the recent trial of former Minneapolis police officer, Derek Chauvin, for the murder of George Floyd, came during the testimony of Dr. Martin Tobin. This Chicago pulmonary physician, in...more

Tell a Story with Your Transactional Documents

I write this blog principally for litigators, but sometimes it is worth remembering that transactional attorneys are also advocates who, depending on the circumstances, may also have persuasive goals. The point of seeking to...more

‘Not an Anti-Police Trial:’ Dissociate When You Need to

This past Tuesday afternoon, the verdict came in for the most closely watched trial in America right now. The Hennepin County jury found former Minneapolis Police officer Derek Chauvin guilty on all counts in the death of...more

Complete Your Jury-Prep Checklist

In the lead-up to trial, a good trial lawyer has many checklists. Some deal with motions to the court. Some deal with disclosure deadlines, some with witness notifications. In this article, I would like to address the broader...more

Disrupt Your Zoom Narcissist

The courtroom trial is one setting where lawyers feel they can sometimes dial up the dramatic delivery. In the hands of some, that liberty can lead to an overbearing style. One question with the newer Zoom environments is...more

Ask Your Doctor If a Jury Is Right for You

We’ve all heard the standard language in drug commercials: After a string of increasingly dire warnings about risks and side effects (a list that seems to nearly always end in “death”), a cheery voice will urge you to, “Ask...more

Don’t Enter That Time Machine: Ask the Question, “What Would You Have Done Differently?”

“Looking back at this situation, what if anything would you do differently?” Witnesses can be asked that question in a variety of case types: medical malpractice, products liability, contract, fraud, and really anything that...more

Witnesses: Don’t Rely on ‘Catcher Signals’

At a recent meeting with a witness to prepare for deposition testimony, and after I told the witness (more than once) to keep their answers short and not to stray beyond the question when answering, the witness asked, “Could...more

Visualize Damages

“Seeing is believing,” and based on the social science, we tend to apply that adage even when the visual aid does not rationally add to the substantive proof. Visuals makes things easier to call to mind later (which makes...more

Add a Plot Twist to Your Trial Story

We know that movie viewers love a plot twist. A surprising turn of events can make a movie memorable, and in films like “The Usual Suspects,” or “The Sixth Sense,” your understanding and perspective on a story can suddenly...more

Don’t Practice til You’re Capable, or til You’re Comfortable — Practice til You Can’t Fail

My daughter is a figure skater — the kind of skater who practices six days a week. Each one of the complex jumps that a skater executes involves dozens of fine-motor movements that need to be encoded into the skater’s muscle...more

Juror Questionnaires: Don’t Worry (So Much) About ‘Helping the Other Side’

During the ongoing pandemic, courts have been understandably reluctant to invite large numbers into their chambers for trial, and particularly for jury selection. That situation has driven renewed consideration of...more

The Virtual Trial: Be Conscious of What Is Lost and What Is Found

The now one-year-old coronavirus pandemic has caused courtrooms across the country to move many of their functions, as well as some full jury trials, into an online space. On the wisdom of that move, there are broadly two...more

The Punishment Profile: Know the Juror Characteristics

As a defendant thinking about your risk in the run up to civil trial, you probably have some idea of what your case is worth. But you also know, and have likely used, the expression, “Anything is possible with a jury.” There...more

The Pizza Scenario: Expect Punishment to be Driven by Both Equity and Retribution

What drives the motivation to not just compensate but to punish? When it comes to considering the purpose and amount of legal damages, the defense will predictably want a jury that, if they get to that stage at all, is...more

Account for ‘Close Counterfactuals’ in Your Trial Stories: The Loser that Almost Won

How bad would it be if, after making it through a year of the pandemic with your health intact, you came down with the virus at the end: You almost got to the point of vaccination, only to become infected at the last moment....more

Address the Causes of ‘Zoom Fatigue’ (and Audience Fatigue Generally)

It has gone from being a surprising observation last spring to a daily truism at this point: Zoom fatigue is real. Now that we are engaged in regular meetings by video web-conferencing, we’ve come to fully grasp the reality...more

Preserve Decorum (in All Courtroom Contexts)

At this point, I will wager that we’ve all seen the hilarious video from the 394th Judicial District Court of Texas, where an attorney, unable to remove a filter that changes his face into a cat’s, nonetheless confirms that...more

The More Things Change….Expect Many Similarities and a Few Differences in a Post-Pandemic Litigation World

We’ve now had quite some time to settle into the coronavirus and its social restrictions. If you are like me, you might have even developed a twitch every time you hear the phrase “New normal.” We know that we are living in...more

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