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Holland & Knight LLP

Podcast - "Ready for Trial?"

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Litigation attorney Dan Small unexpectedly took the lead in prosecuting the high-profile case of the Farmers Export grain elevator explosion, a major incident in Galveston, Texas, that resulted in the deaths of 18 people in...more

Law School Toolbox

Bar Exam Toolbox Podcast Episode 305: Spotlight on Civil Procedure (Part 2 – Discovery)

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Welcome back to the Bar Exam Toolbox podcast! This is the second of three episodes in which we review the substantive Civil Procedure law we've covered in our "Listen and Learn" series.  This time we're talking about...more

Esquire Deposition Solutions, LLC

AI Expert’s Report Deemed Unreliable Due to “Hallucinations” Within

“The irony.” So wrote federal district judge Laura M. Provinzino when she rejected as unreliable an artificial intelligence expert’s report that was found to have contained three non-existent, AI-generated citations. The...more

IMS Legal Strategies

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

Holland & Knight LLP

Podcast - The Basic Rules for Closing Argument

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In this episode of his "The Trial Lawyer's Handbook" podcast series, litigation attorney Dan Small outlines essential rules for lawyers during closing arguments. He speaks about the importance of not misstating evidence or...more

Holland & Knight LLP

Closing Argument: Opportunity and Challenge

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Litigation attorney Dan Small shares insights and strategies for delivering a compelling closing argument in this episode of "The Trial Lawyer's Handbook" podcast series. He explains the challenges of delivering a closing...more

U.S. Legal Support

Bench Trial vs. Jury Trial: Preparing for Each

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When a case proceeds to trial, a legal team may face a critical decision about whether to have it adjudicated by a jury of peers or a single judge. Both options can offer benefits depending on the merits and subject matter...more

U.S. Legal Support

Discover the Benefits of Mock Trials

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Case preparation can take months of research, depositions, and strategic planning—all for that one high-pressure moment in court. Even learning how to write a good opening statement can take a considerable amount of time and...more

Sunstein LLP

Watch Me Pull a Customer Out of My Hat: Proving Damages Using Your Customer’s Out-Of-Court Statement

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Hearsay is simple enough to define – it is an out of court statement offered for the truth of the matter asserted. But practicing attorneys know that the definition of hearsay is deceptively complex. Questions like, “what is...more

Holland & Hart - Your Trial Message

Know Your Trial Message

Trial lawyers understand the need to refine and to help fit the main point of their case into the smallest possible container. In complex litigation, however, that quest for a bottom line can be elusive. You might have your...more

Sands Anderson PC

Fairness in the Adversary Process (Part One): Lawyers and the Discovery of the Truth

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Our adversarial legal system contemplates that each party will have the opportunity to fully investigate the facts of a dispute and bring to the attention of the trier of fact those facts most favorable to its position. This...more

Holland & Hart - Your Trial Message

In Opening, Dispense With “The Evidence Will Show”

Unlike many other moments in trial, the opening statement is often defined in terms of what it isn’t. It isn’t evidence, and it isn’t argument. So, what is it? It is a preview of what the evidence will be. That creates a...more

Nutter McClennen & Fish LLP

Storytelling and Stick Figures: Tips on How to Effectively Present Scientific Evidence in Mass Tort Litigation

Q: Could you describe the process of preparing expert witnesses for mass tort litigation? David L. Ferrera: All federal courts and most state courts require a written expert report, which informs the opposing counsel months...more

Holland & Hart - Your Trial Message

Connect with Jurors: Five Practical Ways

We know that when presenting to jurors, the goal is not just to present, but to engage, to relate, to adapt, and ultimately to persuade. You don’t want to simply lay information in front of jurors and hope they will pick it...more

Holland & Hart - Your Trial Message

Don’t Fret, Your Jury Can Handle Some Complexity

So the case is complex. Maybe it involves a tricky multi-stage legal question. Or maybe it requires understanding some arcane point on patents. Or perhaps it requires grappling with the workings of an unfamiliar technology....more

Holland & Hart - Your Trial Message

Don’t Underestimate Just How Much Jurors Want to Reach an Independent Decision

Add this one to the list of reasons why sequestering the jury can be a problem, and more generally, to the “Juries can do strange things” category. The night before deliberations, at the end of a five-week murder trial, four...more

Holland & Hart - Your Trial Message

Don’t Adapt to ‘Learning Style’

It is part of the received wisdom of popular psychology: People have different learning styles. You reach “auditory learners” by explaining it to them verbally, “visual learners” by showing them graphics, “reflective...more

Searcy Denney Scarola Barnhart & Shipley

Three Card Monte and E-Discovery: Ask the custodians

“But, your honor, we conducted a search and collection from all sources we deemed appropriate and where we believed responsive and relevant information was located…I mean, honest judge.”...more

Gray Reed

Why Videotaped Deposition Testimony can be More Powerful than Live Witnesses

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Although our judicial system historically prefers live witness testimony over testimony of witnesses through a deposition, today’s technology allows even seasoned trial lawyers the ability to present witnesses through...more

Carlton Fields

Efficiency: A Discovery Philosophy, and All You Really Need to Know About Predictive Coding

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The main problem with discovery is the cost. In a very small number of truly bet-the-company cases (for example, where the CEO’s emails must be produced) the greater risk can be failing to do discovery perfectly. But 99 times...more

Troutman Pepper Locke

A Framework for Applying Proportionality in E-Discovery: The Sedona Conference Principles

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The principles provide a useful framework for the application of proportionality to preservation, as well as practical guidance for negotiating the scope of discovery. The Sedona Conference — a research and educational...more

Carlton Fields

Ready for Your Close-up? Five Tips for Using Videoconferencing Technology at Trial

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From a technological standpoint, it is now relatively simple to present live video and audio testimony during a court proceeding of a witness located anywhere in the world. There are many advantages to presenting testimony in...more

Carlton Fields

A Former Appellate Court Judge Offers Tips to Trial Attorneys

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While trial attorneys know they must preserve issues they wish to raise on appeal, they often overlook the basic steps required to help ensure appellate review. During more than 27 years on the bench, former Florida appellate...more

Carlton Fields

Be Wary About A Trial Court's Assurances of Preservation

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Imagine a trial judge is trying to move things along at a charge conference. An issue arises, trial counsel begins to voice objections, and the judge short-circuits the discussion by saying, “Your rights are saved on the...more

Carlton Fields

Before You Push Play – Important Considerations When Using Videotaped Depositions at Trial

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Videotaped depositions can be an effective trial tool. When using video at trial, however, attorneys must remain mindful of the court record. Often, especially for long excerpts, court reporters at trial do not see the need...more

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