- When is the best time to conduct jury research?
a.) Six weeks before trial, after all settlement attempts have failed.
b.) As soon as discovery closes.
c.) Relatively early on in discovery.
- What is the purpose of jury research?
a.) To identify pro-plaintiff versus pro-defense jurors.
b.) To identify our key themes and most effective storyline.
c.) To identify strengths and weaknesses in the other party’s case.
d.) To identify strengths and weaknesses of key witnesses.
e. ) All of the above
- When should you begin to prepare fact and expert witnesses for their testimony?
a.) A few days before trial.
b.) On the eve of their trial testimony.
c.) Prior to their deposition.
d.) After their deposition.
- A 30(b)(6) witness doesn’t need to know many details about the case. The best bet is for them to answer case-specific questions with, “I don’t know,” or, “That’s not my department,” or, “I don’t get involved in those details.”
True – The less a 30(b)(6) witness says, the better.
False – Jurors will expect the corporate designee to have some case-specific knowledge. Otherwise, they will wonder why the defendant did not provide another witness who does have relevant knowledge. If the corporate designee knows nothing about the company’s day-to-day operations, safety training & policies, etc., jurors will wonder who does – it creates the impression of a culture of negligence.
- C-Suite executives do not need to be prepared for deposition or trial testimony.
True – C-Suite executives are already polished, professional, articulate and good at public speaking. They know what to say and will present well.
False – While C-Suite executives may have all of the above characteristics, they may also have characteristics that make them unlikeable or un-relatable to a jury, such as arrogance, impatience, too long-winded or too curt. These witnesses need just as much preparation as any other.
1.) C, relatively early on in discovery
2.) E, All of the above
3.) C, prior to their deposition