Facts are much more than “the placenta tore away from the uterine wall,” or “this ambulance company overcharged the government by over $8,000,000,” or “the light was red.” Systemic and systems-based issues – why this happened – and the pain that what happened here caused - are oft-times more subtle.

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.

Setting out on a journey without knowing where you’re going creates fear, uncertainty, and increased risk. As a trial lawyer when you take a case, you must begin with your end in mind. You must decide at the outset what you want to see happen - how you want your case to end. To begin with your end in mind. Once you do that, the path you’ll take to get there will come into focus. Your steps along that path will be well defined. You’ll be calm, relaxed and in complete control of yourself and your case.

You’re standing in the middle of the courtroom. It’s hot. You feel the perspiration start to bead a little on your temples. Your collar is starting to feel a bit damp too. You just spent the last 3 days picking a jury. You had to fight through countless objections and a judge that firmly believes jury selection should never take more than 3 hours no matter what the case. As deferential as you know you must be, you know too there is far too much at stake here for that.