Advanced Personal Injury Practice

Course Date: November 25, 2004

The Power of Leading Questions

  • forming questions to achieve control
  • avoiding the seven enemy words
  • training witnesses to say “yes”

Controlling Witnesses—One Fact at a Time

  • shaping jurors’ perceptions of the facts
  • using simplicity to block escape
  • fixing the vague question

Goal-Oriented Questioning Sequences

  • encouraging truthful responses
  • putting facts into persuasive order
  • blocking witness evasions

Chapter Method of Cross-Examination

  • dividing cases into understandable parts
  • why one question is not a chapter
  • using facts to change credibility

Using Primacy and Recency to Create Interest

  • persuasion through phraseology
  • telling jurors what’s important
  • breaking the wasted words habit

Page Preparation for Cross-Examination

  • preparation for instant impeachment
  • how to organize cross-examination
  • keeping track of direct examination

Cross-Examination Sequences

  • putting chapters into persuasive order
  • changing the rules of admissibility
  • keeping dishonest witnesses off balance

Loops, Double Loops, Spontaneous Loops

  • how to emphasize your key facts
  • making hostile witnesses adopt your description
  • beating witnesses with their own words


  • expressing theme phrases in trilogies
  • using cross-examination trilogies in opening and closing arguments
  • making the best facts more memorable

Controlling the Runaway Witness

  • 20 methods of controlling the combative witness
  • psychological principles that establish control
  • punishing the non-responsive answer