Posts by pwsadmin

Join me, Sach Oliver, and other outstanding trial attorneys for a 2-day AAJ Education seminar September 19-20, based on Oliver’s new book, teaching a new way of thinking about depositions. The traditional way of thinking, depositions were round one. Round two came with the trial. You will be presented with a new philosophy and methodology…

Everyone knows the basics of a powerful opening statement: tell an engaging story, sequence the facts persuasively, and get out ahead of the defense’s attacks. It may sound straightforward—but it can be surprisingly challenging to give an opening statement that hits every mark. On July 10th, I will be presenting a compelling webinar that helps…

A lot of people have been asking me whether or not former President Trump can get a fair trial in his current NYC case. As someone who deals with jury selection often, my answer to this question is yes I think he can and will get a fair trial. However, I couldn’t do a better…

Jurors often identify with the defendant and often ask questions such as How do we counter these perceptions and concerns? We need to establish that the defendant did not act as a juror would expect. Compare and contrast the defendant’s actions with what the norm would have been. Show the choices the defendant could have…

It’s that time of year. Snow is in the forecast and you break out the four-wheel-drive vehicle for its reliability in the questionable weather. FWD is proven to help you navigate through the unpredictable snow, sleet and ice.  By that same token, we want to be able to rely on deposition testimony as carved in…

Presenting “Advanced Deposition Strategies and Tactics” to the Tennessee Trial Lawyers Association

Presenting to the Tennessee Trial Lawyers’ Association in a full -day session on Advanced Deposition Strategy and Tactics, hosted at Nashville School of Law. The day was jam-packed with information, including developing a discovery plan, basic skills to discover everything a witness knows, depositions of corporate representatives, difficult and evasive witnesses, and medical and other…

As a general principle, the first response of a witness is never everything they know or feel about a subject. That’s why one of the fundamental skills for good depositions is “exhaustion”, asking “what else”, “tell me more” etc. until we are satisfied we have enough to move on. Three years ago, I started studying clean language at the behest of one…