Haytham FarajTed Wacker

Overcoming Significant Hurdles on the way to $21.2 Million Verdict

1. Taking effective expert depositions on video tape to use as cross-examination at trial

2. Selecting the best experts for your case and preparing them for trial

3. Preparing your client and witnesses for their trial testimony

4. The use of storytelling using different scenes for greater impact in Opening Statement

5. Finding all of the problems in the medical records and then finding ways to explain and place into context

6. Using exhibits and visual aids during direct examination of plaintiff and all witnesses

7. The effective use of PPT slides to help educate the judge on the law

8. Recognizing and then handling the perceived “bad facts” in the case and making them your friend

9. The use of friends and family to help tell the plaintiffs story

10. Making sure your life care plan and the expert are providing realistic and reasonable future care costs

11. How to arrive at the damage valuation for the “big ask” in closing

12. Effectively describing the pre-accident and post-accident changes in plaintiffs life (aka “loss of activities”)

13. The best way to handle young children as witnesses at trial

14. When to have the plaintiff appear in the case and attend trial (and avoid eating double bacon cheeseburgers and churros at lunch when you weigh 500 lbs)

15. Capitalizing on mistakes made by the defense (including arrogant defense counsel)

16. What is a rebuttal expert anyway? Using effective motion in limine and argument to exclude testimony

17. Getting in front of bad facts in Voir Dire to neutralize them and exclude biased jurors

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