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Increase Your Witness’s Confidence Level: Seven Ways

Sometimes greater confidence is the last thing a witness needs. When your fact or expert witness is arrogant, unprepared, or careless about their upcoming testimony, they might need a reality check through a preparation...more

Before Your Next Web-Conference, Fix Your Camera Position

If you’re like me, you have been clicking into a ton of web-conferences lately. That’s true of the whole business world, but I think the legal workplace is a natural fit for web conferencing. After all, it is a field that is...more

Web-Conferencing? Don’t Let Your Energy Zoom Away

These days, instead of spending our days in offices, conference rooms, and courthouses, we are likely spending those days in front of laptop web-cameras, negotiating our business lives in this new medium. I have noticed that...more

Find Your Six Ways to Sorry

“Love” may mean, “Never having to say your sorry,” but litigation does not mean that. In some defense cases, sure, what’s needed is an all-out answer that denies everything the plaintiff is saying. But in other cases, there...more

Experts, Know Your Eight Bases of Persuasion

What makes an expert witness persuasive to a jury? Is it their background and training? The work that they did on the case? Their communication skills in teaching the jury? The research suggests that expert influence depends...more

Teach Your Jury ‘Epistemic Vigilance’

“One of the saddest lessons of history is this,” Dr. Carl Sagan once wrote, “If we’ve been bamboozled long enough, we tend to reject any evidence of the bamboozle. We’re no longer interested in finding out the truth. The...more

Add Numeracy to Your Jury

Watching a mock jury deliberate about damages can give you the idea that when it comes to numbers, jurors can be a little random. For example, a jury might see a big difference between $500,000 and $1 million in one moment,...more

Persuade With Your Voice

Trial lawyers are used to persuading with their arguments and with their evidence. But what about the voice? It stands to reason that tone matters, but does it matter enough to influence persuasion? Some attorneys, even while...more

Interview Your Jurors with Purpose: Eight Ways

The chance to interview a juror is a precious opportunity. Whether it is a mock juror interviewed in the course of a focus group or mock trial, or an actual juror interviewed after they are dismissed at the end of trial, an...more

Treat Your Credibility as Central, Not Peripheral

The lawyer preparing their case likely goes through a long list of, “What will they think about…” questions, relating to the facts, the evidence, the arguments, and the law. Eventually, that attorney might get to the...more

Focus on the Focused, but also Deal with the Diffuse

Both theory and experience say that there are two kinds of thinking. One is focused thinking, zeroing in on a topic, analytically and systematically. The other is diffuse thinking, abstract and constrained only by association...more

Don’t Hedge

The habit of sort of just filling in your speech with expressions of uncertainty, when you’re not really that uncertain, is probably a bad habit. I mean, I am fairly sure that these hedges cut down on your perceived...more

Choose Your Persuasive Target

When you stand in front of a jury, laying out your opening story or closing your arguments, who are you talking to? “To the jury, of course.” Yes, but which jurors in particular? The conventional wisdom is that you should be...more

Beware of Extremist Bias

When we engage in arguments, perhaps on social media or even around the table at Christmas dinner, it is easy to notice that there is something different about those at the extremes. Extremists are so filled with confidence...more

Reduce Repetition: Four Ways to Break the ‘We’ve Heard This’ Reaction

Yesterday was an historic day in the U.S. House of Representatives. For more than eight hours, Democratic and Republican members of the body gave short alternating speeches for and against the motion, before impeaching Donald...more

Adapt to Evolving Attention

You’ve probably seen the claim, but is it really true that our attention spans are becoming shorter than that of a goldfish? Last year, the presentation software company called Prezi released its 2018 State of Attention...more

Thank Your Jurors…Just Don’t Go Overboard

I remember once sitting in court early into the defense opening statement, and the attorney was busy thanking the jurors, again. Even though they had already heard the spiel from the other side, and from this attorney’s...more

Be “Tough and Firm” Rather than “Warm and Friendly” in Negotiations

There’s an old expression: “You can catch more flies with honey than with vinegar.” Assuming that your goal is not to actually catch flies, but instead, to get what you want in some kind of negotiation, the expression means...more

Defendants, Include a “Here’s What You Haven’t Heard” in Your Opening Statement Introduction

The law allows counsel on the other side to deliver their opening statement first, so they get the early opportunity to tell you their story. But, there are two sides to every story. And, despite all you have heard, I...more

For Immediacy, Use Active Voice (but for Abstraction, Passive Voice Can Be Used)

You probably learned it in one of your earliest writing classes: Active voice means the grammatical subject is doing the acting, and passive voice means the subject is acted upon. It is the difference between “The dog bit the...more

Address the ‘My House, My Responsibility’ Analogy

There is a persistent belief among many mock jurors that I have seen in certain kinds of cases. The belief is that liability attaches automatically to possession, and jurors usually express it through the lens of home...more

Appreciate the Nuance of a Theme

When you are working on boiling down your message, there will often be that indefinable “something” that makes you recognize when you have the right language. A good trial theme, for example, doesn’t just summarize the...more

Understand Jurors’ Process on Pain and Suffering

Juror 1: “The next category is ‘pain and suffering.’ How are we supposed to get to get that number?” Juror 2: “It is just whatever we want…there’s no guidance for it.“ Juror 1: “How are we supposed to do that? Put a...more

Treat Trust as a Layered Thing

The government often plays a background role in civil litigation. An action, decision, or product from one party might meet the government’s regulations, for example. The question that raises is “Are the regulators trusted?”...more

Speak to the Personal Responsibility Divide

On one end of the spectrum, there are specific beliefs jurors might hold on an issue. More generally, then there are attitudes that cover and predict many of those different beliefs. Even more generally, there is the...more

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