Trial and Mediation Preparation,
Trial Models and Focus Groups

A Mini Seminar On CD
By James W. Harbert CLI, FCI

Many investigators do not know what the term “damages” means. They work on liability. Investigators take statements, photographs, sketch the scene, and prepare reports on who is at fault. Things are changing. Investigators now need to ask questions about how this accident affected those around it. The damages in a civil case are “what is lost.” In the case of a severely injured plaintiff what abilities has he lost, what can he no longer do that he used to love to do? What family activities can he no longer participate in? “What damage did this accident do to this individual or family?” What did the loss of this deceased mean to his family, what type of person was s/he, what were his interests, what about the children, what was his relationship with the children, is there anything to document this relationship? What do the first responders say about the severity of the accident? These areas are just as significant for the investigator as the liability.

In the future, the Legal Investigator is going to have to take on more tasks, be more rounded and capable of many new jobs. Herein lies the value to the attorney. An investigator that understands damages can work much longer on the large cases. The investigator will not be shuffled to the side as soon as the liability case is made and it is time to work on damages. A good investigator can also suggest new ideas to the attorney based on the investigators knowledge of the people and places involved.
How many investigators that specialize in personal injury and wrongful death actually make it into the courtroom with the attorneys? Among the members of NALI how many investigators take a case from the beginning and carry it all the way through to the check from the insurance company.

Terry Cox wrote a very good article in “The Legal Investigator,” Journal for the National Association of Legal Investigators, citing the difference in legal investigators. Some investigators do just what they are told. Others take the file and analyze what has been done and what needs to be done and then they do it. The investigator must prepare himself for these investigations. Preparation comes from attendance of seminars, reading of articles and books on the subject and background work on the specific case. To prepare you must know what has been done and then figure out what needs to be done.

This mini-seminar consists of two power point presentations, one on trial models the other on the making and use of exhibits in court, a detailed article the use of models, focus groups and trial preparation. Featured in the Power Point presentation on trial models is work by Dr. J. Michael Kerrigan, the only known bone model preparation expert in the country. Included also is a 25-question examination.

Trial Preparation
A guide to trial preparation
The file, read every paper in the file, line by line, word by word.
Paralegal’s role in trial preparation
How to train a paralegal to do good trial work.
Anticipating what the attorney needs
Presentation of the case. Charts, power point, models, etc.

How the Personal Injury Trial should be structured:
a. Sequence
b. What’s important, What’s not
c. Preparation of a Personal Injury case for trial.

1. Judges order
2. Discovery cut off
3. Witness list
4. Exhibit list
5. Jury instructions
6. Special Jury instructions
7. Order of proof
8. Subpoenas for trial

9. Organization of the file
a. Witnesses in blue folders
b. Exhibits in Red folders
c. Multiple copies of all documents used in trial

10. Reading depositions should be marked and prepared with a list of what is to be read for the judge and defense.

11. Videos should be organized and ready to play
d. Check out the territory, the courthouse, the bailiffs, copy places etc.
e. Maintaining control of the court room
f. Things to bring to the trial
1. Trial bag
2. Easels
3. Evidence Manual
4. Jury Instructions
5. Rules of court
6. Video equipment if necessary, if not arrange for the use of the courts equipment with the clerk or the Security department.
7. Power point projector and necessary equipment to use it in court.

The witnesses, finding, contacting, and preparing them for trial. Arranging the trial for the witnesses.
Introduction and arrangement of evidence
The preparation of exhibits for trial.
The Preparation and use of models for trial.
The Use of Expert Witnesses, Damage Witnesses and the Police in a Personal Injury Trial.
The use of Focus Groups and/or Mock Trials to determine liability and damages in your Personal Injury case.
Trial Models and exhibits: The Bone Doctor, Dr. J. Michael Kerrigan
Use of models in litigation
How does the attorney obtain a model
Model retailer
Custom built models
Power point presentation on trial models

This seminar is a must for Plaintiff’s investigators, paralegals, legal secretaries, insurance adjusters or risk managers dealing with civil trials or trial preparation. Both professionals and novices will gain much from this seminar. Upon successful completion of the included examination, a certificate of completion will be awarde from the National Association Of Investigative Specialists in Trial and Mediation Preparation, Trial Models and Focus Groups. Pending CE hours in several states.

Trial and Mediation Preparation,
Trial Models and Focus Groups

A Mini Seminar On CD - By James W. Harbert CLI, FCI - $45.00


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