The jury box in U.S. District Judge
Simeon T. Lake’s courtroom.

  1. Don’t ask a witness "do you remember such and such" unless you want her to say no.  Most will take your hint and won’t recall.  Instead posit that "such and such happened, right?"
  2. Do find a way to say "the wisdom of Solomon" when your judge makes a particularly good ruling.  He’ll smile at your insight; don’t do it twice though.
  3. Don’t value persuasion over enemy-elimination in voir dire (selection of potential jurors).  Find the unconvinceable ones and strike them without mercy.
  4. Do agree to adding demonstratives to the exhibit list during trial.  Trust me; you’ll get your best ideas an hour or so before you start cross-examining the other side’s key witness.
  5. Don’t imagine that you matter more than your client.  You care about you.  Your spouse and children care about you.  Heck, Blawgletter adores you.  But the jurors care about doing right.  Help them by leaving your ego at the courthouse door.

Barry Barnett

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