In an era when juror attention spans are shorter than ever trial attorneys must present compact cases. Noted injury attorney Joe Fried advocates adopting a “speed trial” approach. There are steps attorneys can take well before trial to make this happen:
- Serve request for admissions: Many attorneys think request for admissions are a waste of time. I disagree. They can narrow the issues if the other side deals in good faith and admits what it must. If the other side play games, then seek fees against them as the rule allows when you prove the point.
- Take corporate representative depositions: Make the other side produce a corporate mouthpiece. Get familiar with the sanctions available if the other side plays games.
- Don’t waste time authenticating documents at trial: Use requests for admissions, exhibit certifications and records custodian depositions to avoid the waste of time at trial authenticating exhibits. Have that handled ahead of time.
- Use exhibit summaries: Federal Rule of Evidence 1006 authorizes the use of document/exhibit summaries to make voluminous exhibits more understandable. This can be a powerful tool in argument and compresses discussion of each exhibit individually.
Get to the point at trial. Your jurors will appreciate it and may reward you.
