Trial

Sample Voir Dire

• Motor Tort (plaintiff)
• Motor Tort (defendant)
• Transcript of Voir Dire in Auto Accident Case

Opening Statements

• Wrongful Death
• Motor Tort (Plaintiff)
• Full Transcript
• Motor Tort (defendant)
• Motor Tort (defendant)
• Defendant’s Opening #1
• Sample PowerPoint Opening

Direct Examinations

• Direct/Cross of Plaintiff’s Treating Doctor (ankle fracture and soft tissue injury case)
• Direct/Cross of Plaintiff’s Treating Doctor (herniated disc and soft tissue injury case)
• Deposition Outline (premises liability)
• Treating Doctor (femur fracture and cracked ribs)
• Victim’s Wife (spouse if often the key damage witness)
• Victim’s Doctor #2 (outline of treating doctor ACL tear and herniated disc case)
• Medical Doctor in Wrongful Death (pain and suffering witness; decedent was burned to death)
• Accident Reconstructionist (expert claimed speed and alcohol were contributing causes of the accident)
• Neurologist in Brain Injury Car Accident Case (outline for doctor’s testimony on how the plaintiff was brain damages and the long term effects)
• Plaintiff #2 (trial transcript)
• Victim’s Expert (medical malpractice expert – trial transcript)
• Medical Doctor’s Direct (catastrophic injury)

Cross Examinations

• Defendant Truck Driver (cross examination of truck driver in $1 million verdict in Baltimore City)
• Sample Transcript: Direct/Cross of Defendant’s Medical Doctor Expert (Kevin F Hanley, M.D. in a knee surgery case)
• Sample Transcript: Direct/Cross of Defendant’s Medical Doctor Expert #2 (defendant’s doctor in an ankle fracture and soft tissue injury case)
• Sample Transcript: Direct/Cross of Defendant’s Medical Doctor Expert #3 (defendant’s doctor in herniated disc and soft tissue injury case)
• Sample Transcript: Direct/Cross Defendant’s Medical Doctor Expert #4 (Dr. Robert O. Gordon)
• Defendant Driver (outline)
• Defense Medical Exam Doctor (outline cross examination from a presentation given on cross examination of the defendant’s medical doctor)

Sample Closing Statement

• Plaintiff Closing #1 ($8 million verdict)
• Defendant’s Closing
• Plaintiff’s Closing Statement #2
• Sample PowerPoint Closing (PowerPoint in closing)
• Example Day-in-the-Life Video
• Sample Closing Statement (sample closing argument in motor vehicle collision suit from Plaintiff’s lawyer and defense counsel)
• Sample Defendant’s Closing Statement (another closing statement)

Pattern Jury Instructions

• Maryland Tort Pattern Instructions
• Jury Instructions (sought by defendant in a personal injury auto accident case)
• Trial Transcript of Judge’s Instructions

Non-Pattern Jury Instructions with Analysis

• Speeding
• Crash Could Not Be Avoided
• Driving on Divided Highways
• Passing on the Right
• Driver to Control Speed
• Approaching and Going Around Curves
• Approaching Crests of Grades
• Traveling on Narrow or Winding Roadways
• Special Dangers as to Pedestrians or Other Traffic
• Negligent Driving
• Presumption of Negligence in Rear-End Accident (based on Maryland case law that creates a rebuttable presumption that the rear ending driver is at fault in a rear end auto or truck accident case)

Related Topics

• Sample motions in limine
• Sample Closing Statement
• Cross Examinations
• Direct Examinations
• Pattern Jury Instructions
• Sample Voir Dire
• Verdict Sheet

Sample Verdict Sheets and Jury Instructions

• Sample Jury Instructions

Miscellaneous Trial Documents

• Stipulation of uninsured motorist coverage – get a stipulation to avoid the pain of having to prove up your UM case at trial
• Request for Judicial Notice as to Time, Speed and Distance – how far a car travels at a given speed over time
• Examples to prepare and try a tort claim
• Sample trial animation of Plaintiff’s injury