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Tyson & Mendes LLP

Trial Prep: Expectation vs. Reality

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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

Holland & Knight LLP

Podcast - "Ready for Trial?"

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Litigation attorney Dan Small unexpectedly took the lead in prosecuting the high-profile case of the Farmers Export grain elevator explosion, a major incident in Galveston, Texas, that resulted in the deaths of 18 people in...more

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Podcast - Every Case Is a New World

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In this episode of "The Trial Lawyer's Handbook" podcast series, litigation attorney Dan Small recounts his experience as a new prosecutor in the U.S. Department of Justice's Criminal Division, where he was unexpectedly...more

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Best Practices for Using Trial Technology

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Law firms are increasingly using technology to assist and optimize their litigation and trial processes, and this trend will almost certainly continue into the future. In particular, the use of external graphics technologies...more

Holland & Hart - Your Trial Message

Show (a Little) Facial Expression in Court

It is common advice for witnesses in the courtroom or representatives at counsel table: keep a poker face. That advice — avoid scowls, grimaces, and other head-shaking reactions while you’re being observed by a jury — has...more

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Podcast - Getting Dressed for Court

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In this episode of "The Trial Lawyer's Handbook" podcast series, litigation attorney Dan Small talks about the importance of one's appearance while in the courtroom. He especially emphasizes that the wrong clothing can be...more

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Podcast - The Witness Outline

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In this episode of "The Trial Lawyer's Handbook" podcast series, litigation attorney Dan Small discusses the best practices for organizing a trial and questioning witnesses. He highlights that no one approach is the same and...more

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Preparing a Winning Trial Strategy

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Legal discovery often comprises the longest stage of casework—identifying evidence, developing timelines, and vetting witnesses. The facts, strengths, and weaknesses of a case provide puzzle pieces that attorneys identify and...more

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Importance of Testing Your Trial Theme With a Mock Trial

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Akin to a buddy-cop movie—there are some pairings that are stronger together. For trial attorneys, one such pairing is trial themes and mock trials.  A trial theme, also known as a case theme, is critical to simplifying a...more

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How to Write an Engaging Opening Statement

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First impressions are crucial—especially when you’re delivering an opening statement to a court of law, establishing and framing the crux of a case for judges and jurors when a trial begins. Clarity, conciseness, resonance,...more

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Cross-Examination: The Three C’s of Impeachment

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In this episode of "The Trial Lawyer's Handbook" podcast series, litigation attorney Dan Small breaks down the "three C's of impeachment," drawing from his experience in a notable grain elevator explosion case. He highlights...more

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Cross-Examination: How to Effectively Impeach with a Prior Inconsistent Statement

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In this episode of "The Trial Lawyer's Handbook" podcast series, litigation attorney Dan Small explains how to impeach a witness' credibility through prior inconsistent statements. He emphasizes the importance of carefully...more

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Podcast - Cross-Examination: Don't Argue - Elicit Facts

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In this episode of "The Trial Lawyer's Handbook" podcast series, litigation attorney Dan Small explains why eliciting facts, not engaging in arguments, is the most effective strategy when cross-examining a witness. He advises...more

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Podcast - Direct Examination: Getting Rid of Clutter

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In this episode of his "The Trial Lawyer's Handbook" podcast series, litigation attorney Dan Small highlights the impact of verbal clutter in legal proceedings. He stresses the importance of asking concise, clear questions,...more

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The Basics of Opening Statements

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Litigation attorney Dan Small continues his insightful "Trial Lawyer's Handbook" podcast series with a new episode focused on opening statements. Drawing from his extensive trial experience, Mr. Small offers practical tips...more

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Exuding Credibility in the Courtroom

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In this episode of his "The Trial Lawyer's Handbook" podcast series, litigation attorney Dan Small sits down with Frank Vecella, principal at McKool Smith and former head of litigation for Ericsson, for an in-depth discussion...more

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Witness Preparation Tactics to Prep Clients

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Before they swear to “tell the truth, the whole truth, and nothing but the truth,” witnesses need to be prepared for the process and challenges of testifying in a trial, deposition, or other legal proceeding. How you...more

Holland & Hart - Your Trial Message

Witnesses, Make This Your North Star: The Best Answer the Facts Allow

When it comes to witness goals in deposition or in trial, I think there are many useful perspectives. But looking at the range of possible advice, I think there are two bad ends of the spectrum. On one end, there is...more

IMS Legal Strategies

Witness Preparation: Helping Your Witness Avoid Hindsight Bias

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While views may vary, we believe firmly that witness preparation should involve asking witnesses the tough questions, for several reasons: First, we would argue it is better to pose a tough or uncomfortable question up...more

IMS Legal Strategies

Witness Testimony Themes, Cross Examination, & Preparation Consultants – Episode 55

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IMS Senior Jury Consulting Advisor Dr. Merrie Jo Pitera explains why themes are important for testimony, how to prep witnesses for cross, and what attorneys can gain from working with consultants. Listen, watch, and/or read...more

IMS Legal Strategies

Witness Prep Goals, Credibility Factors, & Juror Comprehension – IMS Insights Podcast Episode 54

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IMS Senior Jury Consulting Advisor Dr. Merrie Jo Pitera joins podcast host and IMS Client Services Advisor Adam Bloomberg to discuss the goals of witness preparation, what makes a witness credible, and how witnesses can...more

IMS Legal Strategies

The Reptile Brain Strategy: Why Lawyers Use It and How to Counter It

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Over the years, we have heard much consternation from our clients regarding a plaintiff strategy called the “Reptile Approach.” We have seen this approach become more and more popular—not to mention effective—during...more

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The Universal Experience That Created the Discipline of Jury Research

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As a discipline, Trial Consulting is a relatively new field. Those in litigation who have been doing jury research –– have only been doing so for about 45 years. When I first started doing jury research in the mid 90’s, it...more

Holland & Hart - Your Trial Message

Witnesses, Don’t Create Obstacles to a Positive Perception

Witnesses, I’d like to have a word. You know the most important audience for your testimony — the jurors in the courtroom with you, or the future jury who might someday see a clip of your deposition? That audience is kind of...more

Holland & Hart - Your Trial Message

Take the Medicine: Three Steps to Pre-empting Your Witness’s Bad Stuff

You have your witness on the stand in direct examination. You have finished laying out the positive story that you want to tell, but you have one more thing to do before handing that witness over to the other side...more

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