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Jury Trial Witnesses

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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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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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From the Classroom to the Courtroom: Adopting a Juror-Focused Mindset

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Three years of law school can teach us many things. But what they do not do very well—as we typically discover soon after graduating—is prepare us for the actual practice of law. For those of us who always planned to be...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

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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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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Adapting Trial Graphics to Jurors’ New Media Expectations

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Trial graphics are instrumental in conveying your story to today’s jurors. Presenting an understandable argument to a jury usually involves technology-driven visual communication in the form of demonstrative exhibits and...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

Holland & Hart - Your Trial Message

Witnesses, Know What You Don’t Know: Six Principles for Your “I Don’t Recall” Answer

Michael Cohen, the “Fixer” for Donald Trump, has recently gotten off the stand in the former President’s “hush money” trial. Those taking aim at Cohen’s testimony have pointed out frequent use of “I don’t recall” on many of...more

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Cameras in the Courtroom: Rooting for the Anti-Hero

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We carry not only Netflix and YouTube in our pockets but also the video cameras that make content creation possible. Our neighbors are TikTok influencers with a million subscribers. Our kids are YouTube sensations, streaming...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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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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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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A Peek Behind The Curtain: A Litigator’s Experience Serving On A Jury

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As a litigator, my first legal position was as a Navy JAG, handling cases first as a defense attorney, then as a prosecutor. Since leaving from the Navy, my practice has focused on patent litigation. But I’ve never had an...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

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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

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