Do You Know Your Client's Name?

This may seem like a really obvious maxim, but I just saw it violated in the worst way. I was…


Deposition Strategy: Order of Witnesses

Before you take the first deposition in your next case, you need to spend time doing something that…


The Keys to a Successful Voir Dire

Harper Lee wrote in To Kill a Mockingbird, The only place where a man ought to get a square deal is…


The Overrated Importance of Closing Argument

One of the greatest mistakes a lawyer can make is to save his best argument for the closing…


The Mystery of Jury Selection Solved

Ronald H. Clark and Thomas M. O'Toole have written a masterful textbook on how to pick a jury so…


Two Myths about Cross for Depos and Trial

In a previous blog, I discussed the greatest myth of cross-examination. It is the myth created by…


A Secret to Winning Your Next Oral Argument

It would be naive to think that juries have the final say. Win or lose, an appeal to a higher court…


The Best Kept Secret About Depositions

In contrast to a few decades ago when trials were common, studies show that over 90 percent of all…