Proving Damages to the Jury

Built on a solid foundation of current scientific research and more than 30 years of in-the-trenches trial experience, this 800-page masterwork will help you understand juror biases and motivations, develop persuasive evidence of damages, and talk to jurors in a way that triggers the jurors' natural desire to do what is right and significant by awarding damages to your client.

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ISBN: 9781580123129
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ISBN: 9781580123129
In Stock
Best value
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With this new edition of Proving Damages to the Jury, authors Jim Wren and Laura Brown have updated the book with new and expanded coverage of a broad range of substantive topics, including::

Why Jurors Assess Big Damages

  • Articulate the relevance of post-occurrence conduct to avoid erroneous exclusion of evidence as a “subsequent remedial measure”
  • The direct liability of the organization, in failing to put the safety systems in place that could have averted the accident, can be a more persuasive damages argument than the negligence of an individual defendant

Valuations And Damage Models

  • Updated tables re: computing lost earnings and earning capacity in personal injury/wrongful death cases

Damage Experts and Daubert/Frye Issues

  • Grounds for Frye challenges to expert testimony
  • Daubert relevance and reliability objections
  • Anticipated Revisions to FRE 702
  • Cases re admissibility of expert testimony by life care planners; vocational experts

Discovery Tactics To Maximize Damages

  • Plaintiff’s treating doctor as a key witness

Testing Damages Before Trial

  • Inherent group limitations
  • Virtual testing—screening applicants
  • When to use a concept focus group; a structured focus group; a mock trial

Witness Examination

  • How and when to use day-in-the-life videos on direct
  • New tip for handling an evasive or unresponsive witness on cross

Preparing For Common Legal And Factual Issues

  • Tax effects arguments in physical injury and other types of cases
  • Collateral source evidence
  • Loss of consortium
  • Wealth of the parties

Economic Loss Rule

  • Origin of the “limits on negligence” rationale
  • Updates to Restatement (Third) of Torts: Liability for Economic Harm

And More!

Additional forms materials are available from James Publishing; access to those materials can be requested directly from James by following guidelines provided within the eBook or emailing

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