Time Chart of Potential Mistakes: Jury Selection, Openings, Witnesses and Summations Through Verdict

Jury Selection

  • Be ready for local JCP and TAP rules
  • Having all witnesses under control
  • Watch Batson violations
  • Waiver of jury?
  • Number of preemptory challenges to plaintiff depending on number of defendants


  • Must state a cause of action against every party, including any third-party practice
  • Must state every element of the cause of action


  • Call enough witnesses to make out a prima facie case
  • Qualify your experts
  • Have proof of service of expert reports, authorizations, exchanges of reports, compliance with Preliminary conference order
  • Witness can offer up to date testimony, e.g., physician who has performed a recent re-examination
  • Leading questions, questions whose answer you don’t know
  • Objective and subjective reasons for strategic decisions
  • Preserve issues and objections
  • Offers of proof

Summations Through Verdict

  • Time measure arguments
  • Summing up knowing the judge’s charge
  • Preserve objections to charge, denials of request to charge, objections to summation, mistrial applications
  • Special verdicts
  • Poll jury
  • Inconsistent verdicts
  • Re-submission to jury
  • PJI and hand-tailored charges to the Jury
  • Avoiding prejudicial summation
  • Filing of notice of appeal on verdict in addition to notice of appeal on judgment
  • Make any post-trial motions in a timely manner.

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