Preliminary Sections

• Author: Jim Wren
• Pages: 1-38

HIGHLIGHTS

In the 2016 Edition of Proving Damages to the Jury, author Jim Wren builds

upon his earlier work by providing keen insights into how jurors think about damages,

supported by more than 50 new citations to judicial decisions and cutting-edge legal

and scientific research.

The highlights of the 2016 Edition include new and/or expanded coverage of:

• The importance of avoiding “attacking” language early in the trial to enhance

your credibility with jurors

• Tips for developing new language habits

• The four questions you need to ask to help frame your damages story in a way

that engages jurors

• Why and how to explain intangible damages to the jury

• The steps for computing lost earnings and earning capacity in a personal

injury case

• Two approaches to valuing intangible damages: (1) by analogy, and (2)

emotionally

• Punitive damages in the Supreme Court: Atlantic Sounding Co., Inc. v.

Townsend

• Brain injuries, including updated references to research tools you can use to

expand your understanding of these “hidden” injuries

• The Daubert / Frye dichotomy

• The economic loss rule, in particular changes to the Restatement (Third)

of Torts: Liability for Economic Harm, and the battle over the distinction

between “contractual ELR” and “stranger ELR” claims

• Responding to annuity evidence

• The collateral source rule

AND MORE!

Proving Damages to the

Jury

by Jim Wren

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PROVING

DAMAGES TO THE

JURY

JIM WREN

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