VOICES FROM THE BENCH

Tips from judges on trial preparation, jury selection, trial presentation, witness examination, and professionalism.

Sitting in your office is not the "next best thing to being there."

Failing to make a record can have dire consequences.

Choose your voice and your words carefully.

Stories offered as a reminder to those who practice often in federal court, and as an alert to those who may find themselves there less often.

In the age of diminished attention spans, writing motions with captivating beginnings is key.

An aggrieved party may also request fees shifting for all or part of other attorney fees incurred as a way of punishing the other party for discovery abuses.

Under Rule 30(b)(6), an entity must produce a person with knowledge whose testimony will be binding on the company. What do you do when questions arise about whether the company had designated the proper witness to testify on the company’s behalf?

The proportionality factors in Rule 26 give the court a powerful tool to narrow overly broad discovery requests

Know your judge’s procedures concerning protective orders, and review the case law in your jurisdiction governing orders to seal court records.

A useful and catchy mnemonic to help remember how to prepare for and take an effective deposition.

How to avoid repetition but still be persuasive to a jury.

A jury survey allows jurors to give feedback into areas where you can improve.

A good lead is important, whether it's an opening statements, a motion hearing where you have a limited amount of time, or a presentation to a client.

Tips for thinking on your feet when it comes to making and responding to objections.

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