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   TRIAL PREPARATION FROM START
              TO FINISH




                                   1
   Creating a Trial Notebook

   Preparation Your Witnesses

   Effective Use of Evidence

   Succeeding at Trial


                                 2
Why a Trial
   Notebook?

Which looks better to
you?
Fumbling for
information or finding
it quickly?




                         3
Hard Bound
Notebook

One Notebook
3- hole
Index pages




               4
   Every lawyer has their own method.

   Meet with the trial team and decide what
    goes into the notebook.

   It is not meant to “house” everything.



                                               5
   Use three ring loose leaf lined papers.
   Notes can be placed at initial team
    conference.
   Notes can be added during prepping of
    witnesses.
   At the whim of the attorney in the middle of
    the night.
   During the trial.

                                                   6
   Place all motions in limine from plaintiff (or
    draft if you represent the plaintiff) in this
    section.
   Make sure each motion has a number, not
    just a title.




                                                     7
   Place each defendant’s motions in limine in
    this section.
   Put numbers on the bottom of their motions
    if not provided by counsel.
   If more than one defendant, each named
    defendant gets their own section.



                                                  8
   Place copies of case law that may be used
    during motions in limine hearing.
   Place all copies of case law that may be used
    during jury instruction conference.
   Place all copies of case law that may be
    needed during the course of the trial.



                                                    9
10
   Place all jury instructions provided by the plaintiff in
    this section.
   If you represent the plaintiff, start a draft of jury
    instructions while preparing the Complaint.
   Make sure Instructions show IPI number and
    whether the instruction has been modified.
   Need a number to the instruction, i.e. plaintiff
    instruction No. 1
   Add a section for admitted, denied, or reserved so
    you can check the box during the conference.
                                                               11
   Add a section for each named defendant and
    place their instructions in this section.
   If they are not numbered, do so, it makes it
    easier during the conference to identify
    them.




                                                   12
Witnesses

Front section
should contain a
list of all
witnesses (names,
address, phone
numbers).

Trial subpoenas
with green cards
attached and
placed in
alphabetical order
                     13
   Place all outlines in this section.
   Put them in alphabetical order.
   Have a few copies of each outline for all the
    trial team members.




                                                    14
Exhibits
Front of this
section should
contain an index
of all trial
exhibits
If case is small
enough, place
copies of the
actual exhibits
in this section.

                   15
Complaints

                                                IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT
This section is for a                     
                                                                  DUPAGE COUNTY, ILLINOIS
                        
copy of all             
                        
                            JANE DOE,
                            Plaintiff,
                                                       )
                                                       )
Complaints.                vs.
                                                   
                                                       ) Case No.
                                                       )
                           DR. STRANGELOVE, M.D. ) JURY DEMANDED
                           and HIS CORPORATION, )
                           LTC, an Illinois Corporation,)
Be certain to have         Defendants.
                                                      )
                                                       )
stamped filed copies    
                        
only.                   
                                                                           COMPLAINT AT LAW
                                  NOW COMES the Plaintiff, JANE DOE, by and through her attorneys, BEST PLAINTIFFS LAWYERS
                            IN TOWN, P.C., and for her Complaint against Defendants, DR. STRANGELOVE, M.D. and HIS
                            CORPORATION, states as follows:
Include all Amended                           
                                                                           COUNT I
                                                     JANE DOE vs. DR. STRANGELOVE, M.D.,: NEGLIGENCE
Complaints.             
                           1.       At all times relevant to this cause of action, Defendant, DR. STRANGELOVE, M.D., was, and is a
                            physician licensed in Illinois and practicing in the field of whatever medicine in the middle of nowhere,
                            DuPage County, Illinois.
May include 3rd Party      2.       At all times relevant to this cause of action, Plaintiff, JANE DOE, was under the care and treatment
                            of Defendant, DR. STRANGELOVE, M.D., for the purposes of receiving whatever medicine, care and
                            treatment.
Complaints and          
                        
                            3.       At all times relevant to this cause of action, Defendant, DR. STRANGELOVE, M.D.,

Cross-Complaints, or       held himself out, and otherwise informed the public and the Plaintiff that he possessed the
                                                                        
place in their own
section.

                                                                                                                                       16
 All defendant answers to Complaints and their
  Affirmative Defenses, if any are placed in this
  section.
 If multiple defendants, may place in the order of
  caption, or in the alternative, make separate
  sections for each named defendant.
 Be certain to only place stamp-filed copies into
  the section.
 On index, be certain to include affirmative
  defense if one is pled at the end of the answer.

                                                      17
Plaintiff
Start with
answers to
interrogatories

Then any
supplemental
answers to
interrogatories

Finally all versions
of 213 Answers
with most recent
being last

                       18
Defendants

Start with answers to
interrogatories

Then any
supplemental
answers to
interrogatories

Finally all versions of
213 Answers with
most recent being
last




                          19
   Place plaintiff and defendants Rule 237
    notices in separate sections in the notebook.
   Be certain to review the 237 notices for all
    documents and that required people will be
    available in court.
   Generally these conferences are held
    informally be the parties so that all
    information can be exchanged.

                                                    20
Electronic
Notebook

Best suggestion is to
have the trial notebook
in the same format as
your hard bound
                              Trial
notebook.
                               Notebook
Have back up thumb-
drives with notebook.
Have the actual hard-
bound trial notebook in
reserve.
All kinds of software
available, Exhibit A for
i-pad users to
Sanctions, Trial
Director,I-Blaze
Summation, etc.

                                          21
22
   How to begin?
   Go through all discovery answers, especially
    Rule 213 answers of all parties.
   When completing all abstracts of depositions,
    make sure no one mentioned in testimony that
    should be added to the list of witnesses.
   Go through medical records and other
    documents to be certain all have been identified.
   If additional witnesses are found, immediately
    update answers to Rule 213’s.
   Discuss with trial team and try and scale down
    the amount of witnesses, if necessary.
                                                        23
Preparing your
    Witness for a
     Deposition

Meet with the attorney, be certain
you are aware of what the attorney
expects from the witness.
What documents, if any, would they
attorney like you to show the
witness?
Never show a document to a
witness unless it has been cleared
with an attorney.
Arrange for a time and place to
meet.
Meet the witness alone, in a quiet
place (your office or their home).
Go over discovery answers and
statements, if any.
Go over all documents and if any
changes, let attorney know
immediately.
Remind them of attire.
Remind them to be courteous.
Emotions need to be in check.        24
   Make sure you understand all facets of the
    rule.
   Go over all the answers to Rule 213’s, and
    amendments.
   Check with the attorney for specifics before
    you meet with the witnesses



                                                   25
Lay Witnesses
(f) 1

Lay witnesses may
include:

Your client

Damage Witnesses

Eye Witnesses




                    26
   Make sure they have reviewed their deposition or
    statements, if given.
   Go over all written discovery answers.
   Go over documents produced in discovery, if applicable.
   DO NOT hand them the witness outline or any written
    questions.
   Explain process of trial; direct, cross-examination and re-
    direct.
   Review all exhibits to be used by the witness, if any.
   Answers any questions they may have about the process.
   Take them to the Courthouse.
   Go over Courtroom etiquette.


                                                                  27
Independent
Expert Witness
(f) 2


Independent Expert
Witnesses may
include:

Police Officers

Doctors




                     28
   Be certain you are in a position to be able to prepare them for trial.
   If they are a treating doctor and your attorney represents the
    defendant, you may not speak to them.
   If your attorney represents the plaintiff, you may speak to a
    subsequent treating physician.
   Be certain that the subsequent treating physician is not being
    represented by their own counsel, if so contact their lawyer before
    setting up any meetings.
   For police officers, it is best to call the Chief of Police to get
    permission to speak with the officer.
   Make sure they have copies of their depositions, if taken.
   Be sure that they have reviewed all documents, this includes any
    answers to Rule 213.
   If using demonstrative evidence, get them familiar with them prior
    to trial.


                                                                             29
Controlled Expert
Witness
(f) 3



“Controlled
expert
witnesses”
includes
persons such
as retained
experts.


                    30
 Even though your expert may have testified in
  numerous court cases, the facts and circumstances of
  your case are unique.
 Make certain they are familiar with all the information
  they are relying on as a basis for their opinions.
 Make certain they have reviewed their deposition
  testimony.
 Also go over any opinions that they have previously
  produced.
 Go over any materials they plan on using, i.e. medical
  literature, books, charts, diagrams, and
  demonstrative exhibits and evidence.
                                                            31
Organizing Trial
      Witness
    Information


Be certain their testimony
outline is in the trial
notebook.
Get a box and place
accordion folders marked
with each witness’ name,
role, and phone number, and
place in alphabetical order.
Within each separate witness
folder, place manila folders.
The manila folders contain:
Answers to interrogatories
Mini deposition transcripts, if
available.
CV’s if applicable.
Copies of all exhibits to be
used with the witness at trial.
Copy of the witness outline.



                                  32
33
Choosing your
   Technological
     Direction


Lots of choices:

Pad of paper
Whiteboard
Foam Boards
ELMO Projector
PowerPoint or Corel
Software Trial
Presentations




                      34
   How to begin preparing the exhibit list?
   When abstracting the depositions go over all the exhibits used during the
    depositions and determine those documents you deem appropriate for
    trial.
   Go through all the production request responses, might find by-laws, etc.
   Think about medical records, x-rays, MRI’s, etc.
   Call your experts and see if they want to use some demonstrative
    evidence.
   How about a timeline, will that help the jury?
   Not all exhibits on the list may be actually used at the trial.
   Make several copies of the exhibits and place them in 3-ring binder and
    mark it “Exhibits”.
   Prepare an index of the Exhibits.
   Place number indexes in the exhibit book for easy retrieval.
   Each exhibit will need to be numbered before the trial.
   Prepare an exhibit notebook for the Judge.


                                                                                35
Once the List is
Prepared


Once the list has been finalized
and all the exhibits marked:

Make several copies of the list
so all the trial team members
have their own copy.

Place a copy at the front of the
Exhibit Notebook, the book for
the Judge, and another one in
the Trial Notebook.

The list itself can be used to
track those exhibits that have
been admitted into evidence
and those that go back to the
jury.




                                   36
   Once the exhibit list has been prepared, place all
    the exhibits into the notebook, number them
    and place actual number dividers with the
    exhibits for easy location during trial.
   If exhibits are limited in number, place them into
    the Trial Notebook.
   For more exhibit intensive trials, place them in
    their own notebook.
   Be certain, wherever the exhibits are, that
    multiple copies of the exhibits are available, so
    that the attorney may present them to the judge
    and counsel before using them with a witness.
                                                         37
Demonstrative
Evidence

Demonstrative evidence is
for illustration and
clarification.
Some types of demonstrative
evidence are:

Models
Maps
Photographs
Videos
X-rays
Charts
Medical Illustrations
Graphs
Computer Animations
Timelines
Physical Photo Albums

All of the above can be done
using low or high technology.



                                38
Court Rules and
Practices

Every County has its own
local rules.
Some Judges have rules
that apply to their own
courtroom.
Meet with the judge’s
clerk, bailiff and secretary
and find out what those
rules will be before the
trial begins.
Make certain the attorney
has asked the judge if you
can sit at the trial table,
this is only common
courtesy.
In Illinois, know Rule 213
and how it applies to the
witnesses.


                               39
Jury
Instructions

Illinois has its own set of
Pattern Jury Instructions.
These can be found in:
Textbook
CD
On-line
Notice the instructions are
divided by categories, i.e.
general, damages, etc.
The instructions will need to
be case specific so it will
require changes, deletions
and additions be made
pursuant to the instructions
themselves, or case law.
Some cases have no pattern
instructions, so they need to
be prepared pursuant to the
case law.


                                40
   Once the jury instructions have been drafted, sit down with the attorney
    with the book, CD or on-line and get them done in final form.
   Be sure to place I.P.I. number and Plaintiff’s instruction No. ___.
   With the IPI number add: Admitted, Denied, or Reserved, so you know
    what happened to the instruction after the conference is completed.
   Make another set of the instructions without the number on them, so
    you are prepared at the instruction conference.
   Once you have received copies of opposing counsel’s proposed
    instructions, make sure they have numbers on them as well.
   Place copies of all proposed jury instructions into the Trial Notebook.




                                                                               41
   Take charge of the questionnaires.
   Make Notes.
   Be certain to keep track of where the
    potential jurors are seated in the jury box.
   Observe.
   Keep track of pre-emptive strikes of all
    parties.
   Know who has been removed for cause.
   Discuss your thoughts with the attorney.
                                                   42
Assisting with Jury
Selection


Your job is to assist
the attorney in
identifying those
jurors whose
attitudes and
prejudices will not be
helpful to their client.

What you need to do?

Observe, note,
discuss.




                           43
Tips for Working in
the Courtroom


Meet with the judge’s staff
before the trial and introduce
yourself.
Get a handle on the jury
selection process in advance
of the trial.
Know the rules, motions in
limine the Friday before the
trial begins?
Be polite ,respectful and
ethical.
Pay attention to the judge,
jurors and the attorneys.
Work out logistics with the
attorney before the trial.
Write notes to be given to
the attorney before witness
is dismissed.
Never discuss case anywhere
other than the office.
Never speak with a juror.


                                 44
Surviving the Trial


Trials are extremely
stressful.
Take care of yourself.
Make sure you get as
much sleep as you can,
when you can.
Eat properly and drink
plenty of water.
Keep your emotions in
check.
Lashing out at support
staff or others is
unacceptable behavior.
Think before you speak
if you are tired.
There can never be too
much preparation.


                         45
   Thank you for allowing me to present this
    material to you.




                                                46

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Ipe.may.12.trial.presentation.

  • 1. TRIAL PREPARATION FROM START TO FINISH 1
  • 2. Creating a Trial Notebook  Preparation Your Witnesses  Effective Use of Evidence  Succeeding at Trial 2
  • 3. Why a Trial Notebook? Which looks better to you? Fumbling for information or finding it quickly? 3
  • 5. Every lawyer has their own method.  Meet with the trial team and decide what goes into the notebook.  It is not meant to “house” everything. 5
  • 6. Use three ring loose leaf lined papers.  Notes can be placed at initial team conference.  Notes can be added during prepping of witnesses.  At the whim of the attorney in the middle of the night.  During the trial. 6
  • 7. Place all motions in limine from plaintiff (or draft if you represent the plaintiff) in this section.  Make sure each motion has a number, not just a title. 7
  • 8. Place each defendant’s motions in limine in this section.  Put numbers on the bottom of their motions if not provided by counsel.  If more than one defendant, each named defendant gets their own section. 8
  • 9. Place copies of case law that may be used during motions in limine hearing.  Place all copies of case law that may be used during jury instruction conference.  Place all copies of case law that may be needed during the course of the trial. 9
  • 10. 10
  • 11. Place all jury instructions provided by the plaintiff in this section.  If you represent the plaintiff, start a draft of jury instructions while preparing the Complaint.  Make sure Instructions show IPI number and whether the instruction has been modified.  Need a number to the instruction, i.e. plaintiff instruction No. 1  Add a section for admitted, denied, or reserved so you can check the box during the conference. 11
  • 12. Add a section for each named defendant and place their instructions in this section.  If they are not numbered, do so, it makes it easier during the conference to identify them. 12
  • 13. Witnesses Front section should contain a list of all witnesses (names, address, phone numbers). Trial subpoenas with green cards attached and placed in alphabetical order 13
  • 14. Place all outlines in this section.  Put them in alphabetical order.  Have a few copies of each outline for all the trial team members. 14
  • 15. Exhibits Front of this section should contain an index of all trial exhibits If case is small enough, place copies of the actual exhibits in this section. 15
  • 16. Complaints IN THE CIRCUIT COURT OF THE EIGHTEENTH JUDICIAL CIRCUIT This section is for a   DUPAGE COUNTY, ILLINOIS  copy of all   JANE DOE, Plaintiff, ) ) Complaints.  vs.  ) Case No. )  DR. STRANGELOVE, M.D. ) JURY DEMANDED  and HIS CORPORATION, )  LTC, an Illinois Corporation,) Be certain to have  Defendants.  ) ) stamped filed copies   only.   COMPLAINT AT LAW  NOW COMES the Plaintiff, JANE DOE, by and through her attorneys, BEST PLAINTIFFS LAWYERS IN TOWN, P.C., and for her Complaint against Defendants, DR. STRANGELOVE, M.D. and HIS CORPORATION, states as follows: Include all Amended   COUNT I JANE DOE vs. DR. STRANGELOVE, M.D.,: NEGLIGENCE Complaints.   1. At all times relevant to this cause of action, Defendant, DR. STRANGELOVE, M.D., was, and is a physician licensed in Illinois and practicing in the field of whatever medicine in the middle of nowhere, DuPage County, Illinois. May include 3rd Party  2. At all times relevant to this cause of action, Plaintiff, JANE DOE, was under the care and treatment of Defendant, DR. STRANGELOVE, M.D., for the purposes of receiving whatever medicine, care and treatment. Complaints and   3. At all times relevant to this cause of action, Defendant, DR. STRANGELOVE, M.D., Cross-Complaints, or  held himself out, and otherwise informed the public and the Plaintiff that he possessed the  place in their own section. 16
  • 17.  All defendant answers to Complaints and their Affirmative Defenses, if any are placed in this section.  If multiple defendants, may place in the order of caption, or in the alternative, make separate sections for each named defendant.  Be certain to only place stamp-filed copies into the section.  On index, be certain to include affirmative defense if one is pled at the end of the answer. 17
  • 18. Plaintiff Start with answers to interrogatories Then any supplemental answers to interrogatories Finally all versions of 213 Answers with most recent being last 18
  • 19. Defendants Start with answers to interrogatories Then any supplemental answers to interrogatories Finally all versions of 213 Answers with most recent being last 19
  • 20. Place plaintiff and defendants Rule 237 notices in separate sections in the notebook.  Be certain to review the 237 notices for all documents and that required people will be available in court.  Generally these conferences are held informally be the parties so that all information can be exchanged. 20
  • 21. Electronic Notebook Best suggestion is to have the trial notebook in the same format as your hard bound  Trial notebook. Notebook Have back up thumb- drives with notebook. Have the actual hard- bound trial notebook in reserve. All kinds of software available, Exhibit A for i-pad users to Sanctions, Trial Director,I-Blaze Summation, etc. 21
  • 22. 22
  • 23. How to begin?  Go through all discovery answers, especially Rule 213 answers of all parties.  When completing all abstracts of depositions, make sure no one mentioned in testimony that should be added to the list of witnesses.  Go through medical records and other documents to be certain all have been identified.  If additional witnesses are found, immediately update answers to Rule 213’s.  Discuss with trial team and try and scale down the amount of witnesses, if necessary. 23
  • 24. Preparing your Witness for a Deposition Meet with the attorney, be certain you are aware of what the attorney expects from the witness. What documents, if any, would they attorney like you to show the witness? Never show a document to a witness unless it has been cleared with an attorney. Arrange for a time and place to meet. Meet the witness alone, in a quiet place (your office or their home). Go over discovery answers and statements, if any. Go over all documents and if any changes, let attorney know immediately. Remind them of attire. Remind them to be courteous. Emotions need to be in check. 24
  • 25. Make sure you understand all facets of the rule.  Go over all the answers to Rule 213’s, and amendments.  Check with the attorney for specifics before you meet with the witnesses 25
  • 26. Lay Witnesses (f) 1 Lay witnesses may include: Your client Damage Witnesses Eye Witnesses 26
  • 27. Make sure they have reviewed their deposition or statements, if given.  Go over all written discovery answers.  Go over documents produced in discovery, if applicable.  DO NOT hand them the witness outline or any written questions.  Explain process of trial; direct, cross-examination and re- direct.  Review all exhibits to be used by the witness, if any.  Answers any questions they may have about the process.  Take them to the Courthouse.  Go over Courtroom etiquette. 27
  • 28. Independent Expert Witness (f) 2 Independent Expert Witnesses may include: Police Officers Doctors 28
  • 29. Be certain you are in a position to be able to prepare them for trial.  If they are a treating doctor and your attorney represents the defendant, you may not speak to them.  If your attorney represents the plaintiff, you may speak to a subsequent treating physician.  Be certain that the subsequent treating physician is not being represented by their own counsel, if so contact their lawyer before setting up any meetings.  For police officers, it is best to call the Chief of Police to get permission to speak with the officer.  Make sure they have copies of their depositions, if taken.  Be sure that they have reviewed all documents, this includes any answers to Rule 213.  If using demonstrative evidence, get them familiar with them prior to trial. 29
  • 31.  Even though your expert may have testified in numerous court cases, the facts and circumstances of your case are unique.  Make certain they are familiar with all the information they are relying on as a basis for their opinions.  Make certain they have reviewed their deposition testimony.  Also go over any opinions that they have previously produced.  Go over any materials they plan on using, i.e. medical literature, books, charts, diagrams, and demonstrative exhibits and evidence. 31
  • 32. Organizing Trial Witness Information Be certain their testimony outline is in the trial notebook. Get a box and place accordion folders marked with each witness’ name, role, and phone number, and place in alphabetical order. Within each separate witness folder, place manila folders. The manila folders contain: Answers to interrogatories Mini deposition transcripts, if available. CV’s if applicable. Copies of all exhibits to be used with the witness at trial. Copy of the witness outline. 32
  • 33. 33
  • 34. Choosing your Technological Direction Lots of choices: Pad of paper Whiteboard Foam Boards ELMO Projector PowerPoint or Corel Software Trial Presentations 34
  • 35. How to begin preparing the exhibit list?  When abstracting the depositions go over all the exhibits used during the depositions and determine those documents you deem appropriate for trial.  Go through all the production request responses, might find by-laws, etc.  Think about medical records, x-rays, MRI’s, etc.  Call your experts and see if they want to use some demonstrative evidence.  How about a timeline, will that help the jury?  Not all exhibits on the list may be actually used at the trial.  Make several copies of the exhibits and place them in 3-ring binder and mark it “Exhibits”.  Prepare an index of the Exhibits.  Place number indexes in the exhibit book for easy retrieval.  Each exhibit will need to be numbered before the trial.  Prepare an exhibit notebook for the Judge. 35
  • 36. Once the List is Prepared Once the list has been finalized and all the exhibits marked: Make several copies of the list so all the trial team members have their own copy. Place a copy at the front of the Exhibit Notebook, the book for the Judge, and another one in the Trial Notebook. The list itself can be used to track those exhibits that have been admitted into evidence and those that go back to the jury. 36
  • 37. Once the exhibit list has been prepared, place all the exhibits into the notebook, number them and place actual number dividers with the exhibits for easy location during trial.  If exhibits are limited in number, place them into the Trial Notebook.  For more exhibit intensive trials, place them in their own notebook.  Be certain, wherever the exhibits are, that multiple copies of the exhibits are available, so that the attorney may present them to the judge and counsel before using them with a witness. 37
  • 38. Demonstrative Evidence Demonstrative evidence is for illustration and clarification. Some types of demonstrative evidence are: Models Maps Photographs Videos X-rays Charts Medical Illustrations Graphs Computer Animations Timelines Physical Photo Albums All of the above can be done using low or high technology. 38
  • 39. Court Rules and Practices Every County has its own local rules. Some Judges have rules that apply to their own courtroom. Meet with the judge’s clerk, bailiff and secretary and find out what those rules will be before the trial begins. Make certain the attorney has asked the judge if you can sit at the trial table, this is only common courtesy. In Illinois, know Rule 213 and how it applies to the witnesses. 39
  • 40. Jury Instructions Illinois has its own set of Pattern Jury Instructions. These can be found in: Textbook CD On-line Notice the instructions are divided by categories, i.e. general, damages, etc. The instructions will need to be case specific so it will require changes, deletions and additions be made pursuant to the instructions themselves, or case law. Some cases have no pattern instructions, so they need to be prepared pursuant to the case law. 40
  • 41. Once the jury instructions have been drafted, sit down with the attorney with the book, CD or on-line and get them done in final form.  Be sure to place I.P.I. number and Plaintiff’s instruction No. ___.  With the IPI number add: Admitted, Denied, or Reserved, so you know what happened to the instruction after the conference is completed.  Make another set of the instructions without the number on them, so you are prepared at the instruction conference.  Once you have received copies of opposing counsel’s proposed instructions, make sure they have numbers on them as well.  Place copies of all proposed jury instructions into the Trial Notebook. 41
  • 42. Take charge of the questionnaires.  Make Notes.  Be certain to keep track of where the potential jurors are seated in the jury box.  Observe.  Keep track of pre-emptive strikes of all parties.  Know who has been removed for cause.  Discuss your thoughts with the attorney. 42
  • 43. Assisting with Jury Selection Your job is to assist the attorney in identifying those jurors whose attitudes and prejudices will not be helpful to their client. What you need to do? Observe, note, discuss. 43
  • 44. Tips for Working in the Courtroom Meet with the judge’s staff before the trial and introduce yourself. Get a handle on the jury selection process in advance of the trial. Know the rules, motions in limine the Friday before the trial begins? Be polite ,respectful and ethical. Pay attention to the judge, jurors and the attorneys. Work out logistics with the attorney before the trial. Write notes to be given to the attorney before witness is dismissed. Never discuss case anywhere other than the office. Never speak with a juror. 44
  • 45. Surviving the Trial Trials are extremely stressful. Take care of yourself. Make sure you get as much sleep as you can, when you can. Eat properly and drink plenty of water. Keep your emotions in check. Lashing out at support staff or others is unacceptable behavior. Think before you speak if you are tired. There can never be too much preparation. 45
  • 46. Thank you for allowing me to present this material to you. 46