Table of Contents: Personal Injury Trial Notebook

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Personal Injury Trial Notebook

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From September 2007

Abbreviated Contents

PART I TRIAL NOTEBOOK

Chapter 1 Trial Strategy

Chapter 2 Final Pretrial Preparations and Motions

Chapter 3 Witness Scheduling, Subpoenas and Preparation

Chapter 4 Exhibits: Real and Demonstrative Evidence

Chapter 5 Jury Selection

Chapter 6 Opening Statement

Chapter 7 Direct Examination

Chapter 8 Cross-Examination

Chapter 9 Foundation for Science and Opinion Evidence

Chapter 10 Objections

Chapter 11 Motions During Trial

Chapter 12 Jury Instructions

Chapter 13 Closing Argument

Chapter 14 Verdict and Judgment

Chapter 15 Post-Trial Motions

[Chapters 16 through 19 Reserved]

PART II WITNESS EXAMINATION PLANS

A. Traumatic Injury Cases

Chapter 20 Direct Examination Plan for Plaintiff (Rear End Collision; Leg and Back Injuries)

Chapter 21 Direct Examination Plan for Plaintiff’s Treating Doctor (Slip & Fall With Knee Injury)

Chapter 22 Direct Examination Plan for Plaintiff’s Non-Medical Expert Witness (Mechanical Engineer;
Products Liability)

Chapter 23 Direct Examination Plan for Friendly Lay Witness (Neighbor of Plaintiff Paralyzed in Vehicle Collision)

Chapter 24 Cross-Examination Plan for Defense Medical Examiner (Premises Liability; Closed Head Injury)

Chapter 25 Cross-Examination Plan for Defense Non-Medical Expert Witness (Safety Engineer; Products Liability)

Chapter 26 Defense Cross-Examination Plan for Adverse Lay Witness (Slip & Fall)
[Chapters 27 through 29 Reserved]

B. Medical Malpractice Cases

Chapter 30 Direct Examination Plan for Plaintiff (Missed Cancer Diagnosis)

Chapter 31 Direct Examination Plan for Plaintiff’s Expert (Missed Cancer Diagnosis)

Chapter 32 Cross-Examination Plan for Defendant Doctor (Missed Cancer Diagnosis)

Chapter 33 Cross-Examination Plan for Defense Expert (Delayed Heart Attack Diagnosis and Treatment)