BRACKETING: A DEPOSITION TECHNIQUE TO GAIN IMPORTANT INFORMATION – DISTANCE

In my last blog I examined the importance of pinning down “coached” defense witnesses on measurements that are important to achieving a Plaintiff verdict in areas such as dates, distances, or time. In that Blog I introduced the concept of “Bracketing”. Over the next couple of Blogs I’m going to share some examples from actual deposition testimony.…

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DEPOSITIONS: ESTIMATING DATES, DISTANCES, TIMES, OR MEASUREMENTS

There Are Some Things That You Can’t Let Slide: Bracketing Your opposition will always coach witnesses to avoid answering any question when they are not absolutely sure of something, and they will be specifically coached about estimates of time, distance and the like. As a Result, witnesses often have “difficulty” giving any estimate of something…

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MEDICARE LIENS: HOW TO PREPARE YOUR CASE TO BE IN COMPLIANCE?

Medicare And Hospital Liens I have worked with Advocate Capital and they are top hands in their business. I recently joined them in a seminar where I shared some concepts and tactics I have learned about using focus groups to frame your trial issues. How do you prepare to be in compliance with Medicare Lien regulations?On Thursday, June 25th at…

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MAXIMIZING YOUR RECOVERY

Maximizing Your RecoverySome of you may know that I am presently enrolled in the Executive LL.M in Litigation Management at the Baylor University School of Law and what an interesting experience it has been. This is why I am so excited to tell you about this incredible FREE program for Plaintiff trial lawyers. The speakers for the roundtable…

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DO YOU REALLY UNDERSTAND YOUR JUROR’S ATTITUDES, BELIEFS, AND BIASES

Understanding the Minds of the Jury I begin my book Advanced Depositions Strategy & Practice with a discussion about understanding juror attitudes, beliefs, and biases. Before taking case critical depositions, you need to know and think strategically about the juror’s attitudes and beliefs. Although we all like to think that our communities are unique, there are common…

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CAN A PRE-FILING FOCUS GROUP ALLAY YOUR FEARS ABOUT YOUR BIG CASE

A Pre-Filing Focus Group Can Ease Your Fears I was working with a firm from Chicago this past week. A fine group of experienced trial lawyers and support staff with a personal injury case with serious long-term injuries. As we talked about the case I noticed that some of the staff had some misgivings on…

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HIGHWAY TRAFFIC SAFETY INFORMATION IN A TIME OF PANDEMIC

Highway Safety In A Time Of Pandemic Hello Folks, Phillip here with an update of some important highway traffic safety information that I’d like to share. 100 Deadliest Days We have entered uncharted territory in many ways during this Pandemic, and I have some more bad news and some good news. The bad news is,…

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ADAPTING TO TRIAL PRACTICE IN A PANDEMIC

Greetings to you all. Hope you and your family are well, and everyone is washing their hands a lot! As we proceed into uncharted territory there is one thing that we trial lawyers know and that is we have a duty, a responsibility, to our seriously injured clients to press on as we lead them…

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NEW TECHNOLOGIES AND TECHNIQUES FOR TRIAL LAWYERS DURING THE PANDEMIC

Everyone in this business of ours is now looking to new technologies and techniques to keep our cases moving. My last Blog addressed how I have been working. As a trial consultant, I speak to lawyers across the country on a daily basis and many are concerned about the “how” of doing focus groups online, and what effect…

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ZANTAC: IF YOU USE ZANTAC OR HAVE IN THE PAST PLEASE READ

Zantac Ordered Off The Shelves Amid Cancer Findings I reach out to you during this strange time with hopes that each of you and the ones you love are and will remain safe. As I’ve done in the past I have an important warning about a widely used product that has been pulled from the…

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