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Blog Posts in May, 2015

Defeating the Malingering Defense

In our personal injury trials we need to have strategic methods for defeating any possible defenses which the Defense might put forward. As you begin to work up your case you will slowly destroy the ...
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Arguing Liability in Closing

As a general proposition we, as trial lawyers, seek to demonstrate liability from beginning of trial through closing argument. Our primary mechanism for doing this is by first showing the jurors what ...
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Cross Examination on Industry Standards

We win cases with exceptional cross examination. The reason why cross examination is so powerful is that this is the point in our trial when hostile witnesses can testify to our positive facts. When ...
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Direct your Expert in Injury Trials

When we conduct our personal injury trials we need to decide not only what experts we may need to call on our client's behalf but we also need to consider what subject matter we will need to have ...
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Teaching Liability in Opening

When we present information in trial we need to do so in the most digestible way possible for our jurors. One way for accomplishing this is to establish that there are particular rules which govern a ...
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Basic Motion Practice Structure for Injury Trials

First and foremost, we need to remember the importance of motion work as trial approaches. We want to be limiting issues as much as we can prior to trial. We also want to be limiting objectionable ...
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Story of the Case in Injury Trials

When we conduct personal injury trials we need to remember to be good storytellers. It is too easy to get into the habit of simply proving that specific facts of the case. Although the effective ...
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Discovery in Personal Injury Litigation

Before reading this brief blog/article understand that I, Eric Roy, wrote this blog for my and my staff's benefit. I learned the information contained in this blog from Rick Friedman. If you wish ...
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Your Expert Witness in Injury Trials

Be advised that I write these blogs/articles for my, Eric Roy, and my staff's benefit. Most of the information regarding this specific topic comes from the teachings of Rick Friedman and Patrick ...
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Rules in Injury Trials

I wrote this brief blog/article primarily for me, Eric Roy, and my staff's benefit. I learned these concepts come from Rick Friedman and Patrick Malone who are two of the most successful trial ...
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Defeating Ambiguity in Plaintiff's Injury Trials

I wrote this blog/article primarily for my own, Eric Roy, and my staff's benefit. These concepts were first introduced to me by Rick Friedman who is considered one of the best plaintiff's ...
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Judgment as Matter of Law and Jury Instructions

This short blog/article was written primarily for my own, Eric Roy's, benefit. For a more authoritative and comprehensive explanation of the matter I refer you to the Nevada Civil Practice Manual. ...
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Nevada Civil Trial Rules Continued

There will be circumstances in which our witnesses will not have a strong recollection of the facts we wish them to testify to. This will particularly be the case when you are dealing with ...
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Nevada Civil Trial Rules

This blog/article was written primarily for my, Eric Roy's, own benefit. It covers some of the basic rules governing the setting and conduct of trial in the state of Nevada. For a more thorough ...
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General and Special Verdict Rules

I wrote this short blog/article for my, Eric Roy, own benefit. This is just an abbreviation of some of the Nevada rules as they apply to verdicts in Nevada. For a comprehensive understanding please ...
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Voir Dire and Peremptory Challenges

The purpose of this short blog is simply to shed some light on some of the Nevada rules regarding jury voir dire in civil trials. In Nevada, both sided of the case are afforded unlimited for cause ...
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