Trial practice, discovery, depositions, motions, evidence, expert witnesses, mediation, settlement, and every procedural tool in a California PI case.
The complete trial sequence from jury selection through verdict. California-specific procedure, timing, and strategy.
Read the guide → First impressionsStructure, primacy effect, theme development, and the rules governing what you can and cannot say in opening.
Read the guide → Final persuasionDamages arguments, anchoring, per-diem, Golden Rule prohibitions, rebuttal strategy, and verdict form walk-through.
Read the guide → Building the caseOpen-ended questions, witness control, refreshing recollection, and laying foundations for exhibits.
Read the guide → Testing testimonyLeading questions, impeachment, prior inconsistent statements, and the art of the short question.
Read the guide → Jury selectionChallenges for cause, peremptory challenges, Batson/Wheeler, supplemental questionnaires, and juror profiling.
Read the guide → Pre-trial rulingsExcluding prejudicial evidence, golden rule motions, insurance mention, prior accidents, and attorney conduct limits.
Read the guide → After the verdictJNOV, new trial motions, additur/remittitur, cost bills, and preserving the record for appeal.
Read the guide → Settlement conferencesMediator selection, mediation briefs, bracketing, impasse strategies, and confidentiality under Evidence Code 1119.
Read the guide → Pre-trial resolutionOpening demands, counteroffers, bracket negotiation, policy-limits strategy, and when to walk away.
Read the guide → Finalizing the dealRelease language, indemnity, Medicare set-asides, structured settlements, and minor's compromise approval.
Read the guide → Periodic paymentsAnnuity structures, tax advantages under IRC 104, qualified assignments, and when structures make sense.
Read the guide → Cost-shiftingStatutory offers to compromise, cost-shifting consequences, validity requirements, and strategic timing.
Read the guide → Negotiation mechanicsPolicy-limits demands, time-limited demands, Stowers doctrine analogs, and bad-faith setup letters.
Read the guide → Case financingPre-settlement funding, litigation loans, ethical considerations, and the true cost of litigation funding.
Read the guide → Picking the panelJury questionnaires, voir dire technique, challenge strategy, and identifying favorable and unfavorable jurors.
Read the guide → CACI & special instructionsCACI instructions for PI cases, special instructions, instruction conferences, and preserving instructional error.
Read the guide → Special verdictsGeneral vs. special verdicts, crafting verdict forms, apportionment questions, and inconsistent-verdict problems.
Read the guide → Admissibility rulesRelevance, hearsay exceptions, character evidence, expert testimony foundations, and Evidence Code highlights for PI.
Read the guide → Retained expertsExpert selection, Sargon gatekeeping, designation and discovery, deposition, and cross-examination of defense experts.
Read the guide → Fact-findingWritten discovery, document requests, interrogatories, RFAs, physical exams, and discovery motions.
Read the guide → Oral testimonyDeposition notice, examination technique, defending the plaintiff's deposition, and using depositions at trial.
Read the guide → Written questionsForm and special interrogatories, objections, supplemental responses, and motions to compel.
Read the guide → Deemed admissionsStrategic RFA use, deemed-admitted consequences, motions to withdraw admissions, and cost-of-proof sanctions.
Read the guide → CCP 2032IME procedure, plaintiff rights during the exam, limiting the scope, and challenging biased defense examiners.
Read the guide → Dispositive motionsCCP 437c, moving and opposing papers, separate statements, triable issues of material fact, and timing.
Read the guide → Court motionsDemurrers, motions to strike, motions to compel, ex parte applications, and California Rules of Court compliance.
Read the guide → Pleading challengesGeneral and special demurrers, meet-and-confer requirements, leave to amend, and sustained-without-leave consequences.
Read the guide → Evidence destructionPreservation duties, litigation holds, spoliation sanctions, adverse inference instructions, and independent tort claims.
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