In a recent Q&A conducted by Law360, Partner Chris Arledge sat down to discuss his trial experiences, including the most interesting trial he’s worked, how to deal with unexpected occurrence in the courtroom and how he prepares for trial.

Citing his most difficult trial as his most interesting, Chris discusses a trade-secret misappropriation case in which he represented the defendant, a former employee of the plaintiff who left to start a new business. Chris took over on the eve of trial, and his client had conducted very little discovery and had failed to designate experts to rebut the other side’s expert witnesses.  But, noting the weaknesses in the plaintiff’s damages case, Chris and his team exposed the flaws in the expert’s opinion during cross examination, prevailed, and were able avoid a multi-million dollar verdict.

Chris also mentioned the importance of expecting the unexpected, including witnesses delivering information in a surprising manner, key witnesses breaking down in court or even cell phones ringing in the presence of a judge. “Distractions will come up,” Chris said. “You must find a way to put them behind you and concentrate on the task at hand.”

As part of his trial preparation routine, Chris drafts his opening statement early in the process, preferably before the close of discovery, in order to fully develop the facts necessary for the story he seeks to tell at trial.  “Remember, your goal is not merely to identify the facts that you want on record,” he adds. “You’re writing a play, you’re looking for drama and clarity. You’re looking to tell a story through each witness.”

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