General to specific. For instance, you may want to begin your opening something like this. “I’d like to take you back to January 3, 2018. Wednesday. 3 that afternoon. Here in New York. E Harlem. Metropolitan Hospital Center. Labor and delivery Dept. A patient . . .” General to Specific. Or this, “Today I’m going to tell you the story of a 13-year-old girl . . .” “. . . Do you know who she is?” General to specific.

We start our opening statements with what the Defendants are required to do in this case. The Rules. The Rules broken by the Defendants. That caused, for instance, their patient’s death. I almost always limit my Rules to 3. 3 Rules. At most 5.

Whether the Defendants are required by the Hospital’s policies and procedures, their own Standards of Care or state and federal laws, we want the jurors to know the rules in our case immediately before they hear the facts. We want the jurors to apply these rules to the facts of our case as we tell our story in our opening.

When hospital leadership repeatedly cuts costs to maximize shareholder wealth, a hospital may no longer be safe. While the hospital company shareholders may receive a higher return on their investment and its leadership may make more money, complicit physicians may be endangering their patients and no longer complying with their professional oath.