Trial Consultant & Mediator in Santa Monica, CA providing trial strategy, witness preparation and litigation support...Read More
Preparation of your Voir dire questions is critical. It is important to have thought about the type of a juror you would like to have judge your case. What mix of gender, age, race and background are you interested in getting on your panel? Have a desired profile before jury selection, it will help you strategically when it comes time for the “for cause challenges” and the “preemptory challenges.”
You need to determine what testimony you expect from your witnesses’ depositions and trial testimony before they get deposed. I use a technique that builds the parameters and boundaries of the witness’s actual knowledge of the facts that pertain to the case. This technique builds their “Box Of Knowledge.”
How do you avoid telegraphing? Embrace your facts and take the emotions out of those bad or problematic facts. If you are comfortable with the issues and weaknesses of your case then the message to the jury is “it’s not a problem, just a fact.” Don’t build the facts against your own case let your opponent do their own work.