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Part 5: Evasive Witnesses That Use Spiteful Precision

As a trial lawyer I always hate it when you are taking a defendant witness deposition and they continue to disrupt your questioning by asking you to define the words in your questions. As a trial consultant I have developed several ways to prepare for and approach this type of evasive witness. This category of Read More

Phillip Miller Set To Speak At Southern Trial Lawyers Association in New Orleans

It is with gratitude and humility that I announce that I have been chosen to speak at the Southern Trial Lawyers Association Annual Conference at Mardi Gras in New Orleans. My topic will be: Creating a Trial Story: Three approaches That Work. The 32nd STLA Annual Conference at Mardi Gras is February 19 through 23, Read More

Nashville Trial Lawyer/Trial Consultant Phillip H. Miller Chosen Best Lawyer Best Law Firm

  Nashville Trial Lawyer/Trial Consultant Phillip H. Miller at the Miller Law Offices has been awarded a Tier 1 ranking in the U.S. News – Best Lawyers and the Miller Law Offices received a Tier 1 ranking in the U.S. News – Best Lawyer Best Law Firm in Nashville in the category of personal injury Read More

AAJ Advanced Deposition College January New Orleans

This is the time! Come to our American Association For Justice (AAJ) Advanced Deposition College January 17-20, 2020 in New Orleans. Strengthen your deposition skills with top-notch AAJ faculty in New Orleans at AAJ’s Advanced Depositions College.  This program provides the strategies and techniques to enhance the performance of even the most experienced plaintiff trial lawyer at the deposition table. Read More

Evasive Witness Part 4: Witnesses Who Refuse To Give An Opinion

Evasive Witness Part 4: Witnesses Who Refuse To Give An Opinion This category describes a witness who will no give any opinions, claiming, “I’m only a fact witness.” In this situation, be prepared to have case law available to cite that lay opinion is different than expert opinion, and also that opinion testimony is discoverable Read More

Evasive Witnesses Part Three – The Evasive Expert Witness

Part Three Category 2: The Evasive Expert Witness This is the third Blog in a series covering how we deal with evasive witnesses. You can see those Blogs  here. The examination of experts or other evasive witnesses in a deposition often is reduced to one of two things: 1. An extended argument or harangue of Read More

Highway Safety Update – Things All Drivers Should Know

Phillip Miller here, I hope you are well.  I’ve been thinking about some important issues related to highway safety and I thought you might be interested in checking out a couple of things. Medications and Over the Counter Drugs It is a well-known fact that driving under the influence of alcohol is illegal, but not Read More

Evasive Witnesses Part Two – “I Don’t Know”

Dealing With Evasive Witnesses Part 2 – “I don’t know” In my last Blog, I talked about dealing with a deposition where the witness, for whatever reason, will not provide reasonably fair and honest testimony. We looked at the dozen most common evasive, uncooperative behaviors from these witnesses and here we provide suggested techniques for Read More

Deposition Preparation – Dealing With Evasive Witnesses

Dealing With Evasive Witnesses Laziness and lack of preparation can doom any discovery effort. You may have taken this kind of deposition before and everything went great, but this time, the witness seems unmanageable. You seem to be doing everything right, but you are not getting anything. The most obvious conclusions and the answers that Read More

Picking A Jury With Older Jurors Requires Special Scrutiny

An Interesting Study About Older Jurors As a Plaintiff ‘s lawyer, who doesn’t want an easy rule of thumb for selecting plaintiff friendly jurors? Sorry, there isn’t one. Nonetheless, there is research that suggests we need to look more closely at older jurors we might not spend enough time with during this important phase of of our Read More

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