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Jury Trial Defense Strategies Depositions

Tyson & Mendes LLP

Trial Prep: Expectation vs. Reality

Tyson & Mendes LLP on

When I first decided I wanted to become an attorney, I did not think about being in trial. Even in law school, I gave little thought about what it would mean to be in trial. Like a lot of people, my experience with being in...more

Marshall Dennehey

Strategies for Combatting Reptile Theory in Medical Malpractice Trials

Marshall Dennehey on

The Reptile Theory is a litigation strategy intended to activate jurors’ survival instincts during trial and is designed to induce fear over logic and reason when hearing a case. Rather than focusing on the standard of care...more

Holland & Hart - Your Trial Message

Prepare for Multiple Choice Questions in Deposition

Anecdotally, I have seen it in a few recent cases: The deposition witness isn’t asked an open-ended question and isn’t given a “Yes or No” either. Instead, they are given a range of options, like you would see in an attitude...more

Holland & Hart - Your Trial Message

Know the Other Side’s Three Goals for Your Deposition

So, your deposition has been scheduled, and you’re just starting to wrap your head around what is in store for you. Your lawyer has already stressed that you are not in the driver’s seat at this stage: The deposition is the...more

Holland & Hart - Your Trial Message

Apply Two Tests to Any Battle Between Stories

It’s America’s case of the moment: Johnny Depp and Amber Heard, Hollywood’s former power-couple, now exchanging accusations of physical abuse in a Fairfax, Virginia courtroom. The defamation case initially brought by Depp has...more

Holland & Hart - Your Trial Message

Know How Your Testimony to the Jury Will Differ from Your Deposition

A typical witness preparing for a civil trial often has only one good reference point for what their experience will be, and that is their deposition. That’s where they met opposing counsel, got a taste of that attorney’s...more

Holland & Hart - Your Trial Message

Opening: Build Your House First, Then Take Aim at Their House

I have worked with more than one defendant who simply could not resist it: Right out of the gate, in opening statement, they come out swinging against the plaintiff. They’re not being honest, they have their own share of...more

Holland & Hart - Your Trial Message

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

Holland & Hart - Your Trial Message

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

Holland & Hart - Your Trial Message

Examining Attorneys, Keep Your Cool

So you’re conducting the cross-examination, and the witness is fighting like a three hundred pound marlin at the end of your fishing line. And they’re not fighting by legitimately drawing distinctions or by using their own...more

Holland & Hart - Your Trial Message

Witness Testimony: Understand the Confidence/Competence Circle

For someone starting out in a career, or in some other situation where credibility will be required, there is an expression: “Fake it until you make it.” In other words, if you act like you’ve got it, then people are going to...more

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