News, views and tips on litigation graphics, trial strategy and the law.

How to Guide the Jury Through the Verdict Form in Closing Argument

layersIn closing argument, it can be effective to show the jury the verdict form and tell them how you hope they fill it out. This technique is particularly important when the jury will face a complicated, multi-page special verdict form—introducing the jury to the form may avoid errors that will be costly to clarify later.

Below is a sample verdict form for a trade secret case (adapted from the General Verdict form VF-5001 in the Judicial Council of California Civil Jury Instructions (“CACI”):completed verdict form for trade secret

In this post, I’ll provide an example of what an attorney might be saying as this graphic builds during closing argument. For the tech-lovers among our readers, I’ll also talk a bit about the use of Adobe Illustrator to create the graphic.

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5 Key Tips for Trial: Judges Tell Attorneys What They Do and Don’t Like In Court

Judges really do get to see it all when it comes to the good, the bad and the just plain ugly of attorneys trying cases. Yesterday, I attended The Recorder Roundtable: “From the Bench - Outstanding Trial Work” in San Francisco, where sitting judges offered great tips for all level of practitioners about what judges do and don’t like to see in trial. The participating judges were the Hon. Teri Jackson of San Francisco Superior Court, Hon. Jo-Lynne Lee and Robert McGuiness of Alameda County Superior Court, and the Hon. Rise Pichon of Santa Clara County Superior Court. I’ve summarized their top five tips below:

1. Motions in Limine: Beware and Use Sparingly

Lawyers love ‘em and judges hate ‘em. Well, this is a bit of an overstatement, but the judges dislike some practices in this area. They cautioned attorneys that the Motions in Limine are often the first impression any judge has of an attorney, and as with everything, presentation, organization and content matter. [Read more...]