About the voir dire process: Key points to remember
An experienced attorney probably has some favorite Voir Dire questions. However, those questions that have worked in the past may be less than ideal for the case in front of you. Write out the question, practice it by asking your colleagues and listen to their responses in judging if the question needs modification or reconsideration.

Voir Dire Fact Sheet – Part I
Make yourself a score card. Know how many challenges you have and keep track of the ones you use as you go along in the process. If you have staff ask them to review news on the web that speaks to the community in which you are trying your case. If you have the budget consider a focus group for cases that hinge on special issues such as race, gender, and sensitive topics that reflect community values.

Voir Dire Fact Sheet Part II: First day of trial
Although you are probably pre-occupied with motions, witness orders, stipulations and just the mass of information about the trial, don’t leave Voir Dire to chance. If you have an assistant or an associate plan a week or so before the day of Voir Dire. Have your notebook with a jury seating chart ready, have your questions printed in BOLD 16 point font and ask the questions out loud to yourself three times so you familiarize yourself with them beforehand.

Voir Dire Facts Part III: Key points to consider the day of
Some key points to consider the day of voir dire.

Voir Dire Theme Development Fact Sheet
In order for people to make sense of the world around them, they often use stories to organize events and give them structure. Jurors in a courtroom is not any different, for the attitudes and experiences they bring with them play a role in determining the types of stories they construct to better understand the facts and arguments presented at trial.

Jury tips: Setup a Shadow Jury
After completing the voir dire process, you will hopefully have a jury favorable to your client’s needs. Many lawyers stop here and hope for the best in terms of how well their information comes across to the jury.  However, if you want to know how the jury is understanding your information, or areas that are confusing, you could set up a Shadow or Mirror Jury.

Jury trial tips: Constructing an opening statement
When using a model story, or theme as the foundation for your case, you will want to begin telling your story the first chance you have to talk to the jury. Except for what jurors may have learned through voir dire, you are essentially starting out with a tabula rosa, a blank slate. Thus, the opening statement becomes critical in giving the jury a sense of the case.

Jury Trial Tips: Closing Arguments
When it comes time for closing arguments, the jurors will have spent the course of the trial forming impressions and opinions about the evidence and your story. It is important that you remain consistent with your story; for your closing argument is a culmination of what has transpired. Hopefully, your story will have created an outline for which the jury can use to connect-the-dots, with the last dot being a favorable verdict.

Presenting to the jury: Use of demonstrative evidence
After a thorough investigation and careful preparation of your client’s case, you want the jury to understand the information being presented to them. One way to enhance the impact of this information is through the use of demonstrative evidence.

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