Plaintiff Trial Lawyer Tips

OCTOBER 31, 2024

THREE PRIMARY DEFENSE CLAIMS __ __ __ PLAINTIFF PROOF OF CAUSATION __ DEFENDANT CAUSATION DEFENSE _ PRELIMINARY STATUS REVIEW  Review local rules regarding deadlines and requirements DISCOVERY REVIEW Interrogatories  Review defendant’s answers to interrogatories. Note incomplete answers for motion. Supplement if needed.

Cross-Examination 100

Cross-Examination Exhibits Interrogatories Opening Statement 100

E-Discovery LLC

MAY 19, 2025

Self Help Discovery Results in Striking of Wrongfully Obtained Evidence (Mar. The Court wrote that: Eventually, the parties both filed discovery motions seeking access to Plaintiff’s now-located cell phone, with the Court ordering a forensic examination of the phone, the SIM card, and Plaintiff’s iCloud account.

Evidence 130

Evidence Discovery Jury Instructions Litigation 130

Sound Jury Blog

JANUARY 8, 2024

Initial Case Strategy “I resolve to start thinking about my jury story BEFORE discovery even starts.” Too often we see trial teams begin thinking about their jury story near or at the close of discovery. Patton Jury Research “I resolve to make time to test my case through a focus group or mock trial.”

Litigation 52

Litigation Jury Selection Depositions Closing Argument 52

E-Discovery LLC

NOVEMBER 29, 2024

Discovery had been conducted for almost a year and the deadlines extended three times. Doe complained of alleged piecemeal document production and, after deposition, “grew concerned” that relevant documents had not been produced. 5, 2024); Discovery About Discovery – When Was Duty to Preserve Triggered? See Goodman v.

Burden Of Proof 130

Burden Of Proof Evidence Discovery Litigation 130