The Barrister’s Toolbox
A Resource for Trial Advocacy
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Helping Your Client Connect with the Jury
The more significant a witness is to your case, the more important it often is to let the jury know exactly who they are. Usually, your client is one of the most important witnesses the jury will hear from during the course of trial. When dealing with such witnesses, I will generally cover age, where…
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Teaching Your Client How to Mind Their Manners While on the Stand
It costs you nothing to be a gentleman or lady. However, a lack of civility can be very costly. The manner in which a witness or party testifies is critical to their credibility and understandability to the jury. You want witnesses to testify in a natural manner, but they need to be understood and well…
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Witness Preparation… You only get one chance to make a good first impression.
Yes, appearance does count! I’m always amazed when witnesses or parties appear in court and are dressed like they’re going to be working in their yard or are going to a dive bar. First impressions are lasting impressions. Before your client or witness says a word the jury or judge will be sizing them up…
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Closing Argument – Shelving Some Good Ideas
What are some other resources I should consult? Here is a list of books dealing directly with closing arguments that should offer both guidance and inspiration: Polarizing the Case: Exposing and Defeating the Malingering Myth by Rick Friedman: This book provides an innovative approach to trying cases. Too often we allow the defense in personal-injury…
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The Million Dollar Question: How Much Should I Ask For?
There is no set rule. I would recommend that you play it by ear. If you have a case that is clearly worth a good deal of money, give the jury guidance as to how you calculated damages by breaking down each separate category covered in the jury instruction on damages and assigning a number to it.…
The Barrister's Toolbox 