Kurt Zaner

We would all love to have days to conduct Voir Dire, but sometimes you just get thirty minutes, or worse, 15 minutes. In Colorado, and in federal courts in Colorado, 15 minutes is the standard. In this time, you have to establish rapport, find the bad apples, and plant seeds for concepts like money for pain, burden of proof, and introducing large damages. How to do it in 15 minutes or less is an acquired skill.

In this hour we will go over exactly how to do it, including how to memorize juror’s names, how to speak to everyone, and pitfalls to avoid. And, perhaps most importantly, how to introduce the idea of large damages in a diffusing way. In my last trial, with 15 minutes of VD in federal court, I told them I would be asking for 40 million dollars and no one batted an eye (they ended up awarding 30 million). Then, I will also cover different ways and formulas at the end of closing to argue for large non-economic and impairment awards – including the per diem, multipliers of economic damages, the “trust me” method, and other creative approaches.