1

Stop Talking So Much!

Never say one more word than the moment requires. You will appear like you have too much of an agenda or like a used car salesman. This is time for you to learn about the jurors not for them to judge you, your client, the evidence in the case and whether the case has merit. Less is best. Stick to the basics and keep it moving. Begin with an introduction of your self, the parties and the nature of the case. Explain how the process is intended to work and briefly state your sides contentions. Get right into the business of selection by floating some concepts and ideas as a pre-cursor to asking open-ended questions directly to the jurors.

2

When You Do Talk Make It Count.

Every lawyer knows that there are only 3 times when you can turn and speak directly to the jury. Selection, opening and summation. When you are talking you are furthering your agenda and imparting your theme/theory, key principles or defense into the jurors minds. Also, use the operative language that they will hear in the Courtroom. Particularly when it comes to the elements of proof. For example, use "substantial factor" as opposed to proximate cause on personal injury cases. "SF" is the language the judge will use when charging the jury, so make them familiar with it early on and getting them understanding that this is a low threshold.

3

Listen To What You Don't Want To Hear.

There are jurors who are emphatically opposed to your defense or case. That is okay. Allow that juror to express his/her view. Then graciously and humbly thank them for their bold honesty. Make sure their position against you is firmly cemented such that your adversary will be unable to 'rehabilitate' them and keep them on the panel. Ask fellow jurors if they agree with this jurors views. This will stimulate a dialogue and allow you to see who may be good for your case or outright damaging.