Trial Practice

Establishing the record

An appellate lawyer’s perspective on what trial lawyers need to know about preserving their records for appeal

How defendants misrepresent a plaintiff’s condition through social media

Key laws to protect your plaintiff from prejudicial evidence at trial through motions in limine

Direct examination requires its own storyline sequence with a beginning, middle and end

A look at the elements of a real apology, and how to avoid a tactical apology at trial

From Issue: 2017 May

You can try to keep it out, but that “impeachment” evidence is probably going to get in

From Issue: 2025 July

Calling a defense witness as your first witness is a popular idea – and a bad one

Six tips from an appellate lawyer about how to minimize the risk of inconsistent verdicts

The importance of “bookmarks” in your electronically filed documents, and the properly tabbed courtesy copy of your printed filing

From Issue: 2019 July

Telling your story using demonstratives and evidence

Some perspective from an auto-insurance adjuster turned plaintiff attorney

From Issue: 2021 June

Thoughts on closing argument, risk, and letting jurors feel the loss

From Issue: 2026 April