1. Don't talk about yourself. No one cares if you have kids, are married or named your dog something cute. Just because people may like you does not mean they will vote for you.
2. Don't insult members of the jury pool. True story: I saw a lawyer ask potential juror, "There will be complex scientific testimony in this case. Do you think you can understand it?"
3. Don't decide to reject a juror based on surface attributes. True story: One potential juror was a 60-year-old female engineer; my key witness and corporate representative was a 60-year-old female ad executive. The engineer made the jury and voted against us (she was in the minority, 10-2). Why? The case involved the importance of being precise. That mattered a lot more to the engineer than being in the same cohort as my corporate rep.




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