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Witness Preparation Witnesses Jury Trial

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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

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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

IMS Legal Strategies

5 Tips for Med Mal Expert Testimony from a Hot Seat Veteran

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As a presentation technology consultant, I have been sitting in the hot seat for almost 25 years. I average one trial a month with about 75% being medical malpractice (med mal) cases. I work with both plaintiff and defense...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

Holland & Hart - Your Trial Message

As the Reptile Evolves, Update Your Understanding of ‘Duty’

The Reptile approach to courtroom persuasion aims to sell plaintiffs’ cases by invoking absolute duties for protection wrapped around a fear appeal that resonates with the jurors. Even with the Reptile’s ‘reboot’ version, the...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

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

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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

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

Holland & Hart - Your Trial Message

First Answer in Direct: Introduce Yourself to the Jury

As you are putting on your case at trial, and you go to call your next witness, there’s always a reaction from the jury box. It’s an opportunity for fresh attention from them, but it is often a bit of a mystery...more

Holland & Hart - Your Trial Message

Witnesses: Know that Certainty Matters as Much as Accuracy

When thinking about the title for this post, I came awfully close to saying that certainty “matters more” than accuracy, but I thought that perhaps it might sound too cynical. But that stronger version is supported by the...more

Holland & Hart - Your Trial Message

Witnesses: Protect Yourselves Against the “Just Answer Yes or No” Instruction

It sometimes happens in the course of testimony: After what might have been a longer or misdirected answer, the witness will receive a stern admonition from either the questioning attorney, or worse, the judge...more

Holland & Hart - Your Trial Message

Understand the Full Effect of a Bad Connection or Recording

The persisting pandemic has brought with it more adventures in technology. Courts have seen an increased use of remote testimony and oral argument, and even fully remote trials. When it is done well, it can be surprisingly...more

Holland & Hart - Your Trial Message

Witnesses, Don’t Be Surprised by Surprises

So you’re preparing for your trial testimony, and the discovery has been voluminous. Out of the mountain of documents that opposing counsel might wave at you, there are a handful that are most likely to be relevant to you....more

Holland & Hart - Your Trial Message

Your Direct Examination: Know the Steps, but Let the Attorney Lead

When preparing for trial testimony, often the focus is on what opposing counsel is going to do. You prepare for cross, naturally enough, because that is an adversarial moment. But my own view is that direct examination should...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

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