First, The Storyteller.

As a trial lawyer you’re first, the storyteller. You tell your story in your initial complaint, in every deposition you take, in every pleading you file. You tell your story at trial, in your opening, with every cross, and when closing. You tell your story every time you file a motion or response. Whatever you file is about whatever you want it to be about – your story. It matters little what your opposition wants to waste time about, oft times to distract jurors and the court form the real story. Spend your time on your story. What your story is really about.