The first time you try a case shouldn't be in front of a real jury. Geoff Hamby, a partner at Oliver Law Firm, rehearses jury selection and opening with mock jurors — two rounds a day across two days — in the trial venue before pulling the trigger. His firm even starts wearing suits 30 days out to get into the right mindset. Hosts Caleb Miller and Eleanor Aldous unpack the preparation behind Geoff's $5.3 million verdict against First Student in Portland, Oregon, in only his second first-chair trial, and how he passed a Sharpie-marked brain around the jury box. Tune in to learn how relentless preparation can turn trial nerves into readiness.

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More likely than not, that 0.01% is all it takes to tip the scales of justice. Join us as Inner Circle legend Charla Aldous, Eleanor Aldous, and Caleb Miller walk you through the critical moments, big decisions, and bold strategies that win high stakes cases and show you how to turn that 0.01% into a game-changing verdict. You're listening to the podcast where winning is More Likely Than Not, produced and powered by LawPods.

Hi, and welcome to another episode of More Likely Than Not. I am joined today by Eleanor Aldous and our special guest, Geoff Hamby. Hey Geoff, how are you doing?

Fantastic. How are you guys?

We're good. And so for all of you listening who don't know who Geoff is, Geoff is a partner at Sach Oliver's firm in Arkansas, and we wanted to have him on today because he just got a $5.3 million verdict in Portland, Oregon, and Sach was so stoked how well he did that he wanted to email us and he told us all about it. So once we heard about the trial and kind of heard about the case, we though it would be a good idea to have him on. And so that's what we're going to do today.

Geoff, this is my first time actually meeting you. I'm so excited to do this podcast with you and get to know you a little better, but let's introduce you to me as well as the listeners. I think you were born in Arkansas, is that right?

That's right. Yeah, born and raised all in about a two-hour circle up here in the west half of Arkansas.

Oh, really? Is there a fancy way people say Arkansas and Arkansas or is it just Arkansas?

It's Arkansas. We're actually the only state in the union that has the correct pronunciation of our state in our constitution. So it is not our Kansas. For anybody who's wondering, it is Arkansas.

I love it. Yeah. See, I knew there would be a funny answer to that one. That's great. And you went to the University of Arkansas, is that right?

Yep, that's right. Born and raised, razorback, never even applied anywhere else. Went there for undergrad and law school. Didn't miss a home football or basketball game for all seven years. So I'm all the way in.

That's impressive. So have you just been in Arkansas your entire life, it sounds like?

Yep. I was born down in the River Valley, like I said, and then moved up here in 2008 to go to school and been here ever since. Live here with my wife and kids now in Rogers. Awesome.

How long have you been a lawyer?

11 years. So I graduated in 2015. 11

Years.

So I just hit that 11th year.

How did you become a lawyer?

Well, my dad is a ER doctor and then my mom went to law school. So she is actually the one who kind of introduced me to it. She went to law school later in life, and so I was already in middle school by the time she was going. And there was one time when there was a snow day, and so the middle school was closed, but the law school was not. And so it was about a 45-minute drive from our house to the school. And she said, "Hey, there's nowhere for you to go. You're coming with me to go to class." And so on the drive up, it was actually, she had a civil procedure class that she was going to first. And on the drive up, she had me read her cases to her and we talked about what the findings were that they were trying to get, what the conclusions was.

That's a good sign right there.

Yeah. And so I'm sitting there as a 12-year-old reading through all these civil procedure cases, and then we go into the class and the professor's talking about what the assigned reading was. And he says, "So what was the holding in this case?" And somebody gives the answer and he says, "Yes, and I think they're wrong." And so I raised my hand as a 12-year-old to try to say, "No, no, no, that's not what the case actually said. It said something different." And I raised my hand and he just laughed at me. And so I knew from that point it was like, okay, I'm really interested in this and I like doing it. So just kind of was on that track from middle school.

Here's the question I have. What gave you the confidence at 12 years old to raise your hand in a room full of people way older than you and all that? Was that from your parents, from your innate sense of self? Where'd you get that from?

It's a really good question. Probably just unearned confidence. I don't know where it really comes from. I've always been comfortable talking in front of people and sharing my opinion and trying to say what I think. So it's just always been something literally from as long as I can remember that I've liked to do.

I was thinking though during that question as a parent myself, I mean, was your mom trying to put your hand down the entire time? Please don't embarrass me.

Yeah. As soon as it went up, she reached over and started, this was before a lot of correct stuff was going around, trying to slap me in the back of the head and all that stuff. So it was definitely an embarrassment for her, but it was a good memory for me. And I actually ended up having that professor whenever I went to law school, Professor Howard Brill, he's pretty famous around Arkansas, but it was a great time. No way.

Did you tell him the story when you were in his law school class?

I did, yeah. And he did not remember that moment, but he did remember my mom bringing me to class. And so he was about 13 years later, 14 years later, whenever I was in his class, but he actually is still there today, another 11 years past that. So he's been around for a while.

Wow, what a bittersweet memory. All right, so how did you become a trial lawyer though? Because we all know there's so many different areas of law you can go into. Did your mom end up practicing as well?

No, she actually just went to school because she wanted to help some friends with adoptions and that sort of stuff. She never really intended to be a full-time practitioner. It was just kind of something she wanted to do. But like I said, my dad was an ER doctor, and so I went into law school wanting to be a med mal defense lawyer.

Oh, okay.

Thinking I was going to go defend these honorable doctors against these dirty ambulance chasers and all this kind of stuff, and got into law school and saw how the system actually works and who the clients are on both sides when it's not actually the doctors and all that sort of thing. And then I knew at that point I was interested in getting up in front of a jury and talking and was leaning more towards this side of the aisle or this side of the V before getting a job here.

What made you lean towards that side of the V? Was it something personal or was it more about your career ambitions or what drove you to that side? Because everyone has a different reason for joining this side.

My personality fit really was the biggest thing. I knew I was not the kind of guy who was going to want to go and track what I did every six minutes and do all these sort of things, the hoops that you have to jump through to be an insurance defense lawyer. And I felt like I fit on this side. And then the people that I met through networking opportunities, our local Trial Lawyers Association, that sort of deal, I really clicked with them as well. And so it was just more of a lifestyle and personality fit than anything.

Got it. And how long have you been at Oliver Law Firm now?

12 years actually. So I started here while I was still in school. My funny story is these are the only folks who would hire me when I was trying to be a clerk. I've got a stack of decline letters in my closet over there from, I literally would drive around from firm to firm with an application trying to get a clerkship my second year of law school. And I got an email from the lady who handled the career services at the university said, Oliver Law Firm's looking for a clerk. And so okay, sure. I saw them come and talk to the mock trial group. And so I submitted my application in and came and did an interview with Ryan and they hired me on the spot. Said, sure, you got to come here and clerk for us. And so at that point, I just really loved the culture and fit in and wanted to be here for as long as I could see.

Now, whether they wanted me here the whole time is probably a different question. You're

Still there though.

I am still here now. Yeah. My 3L year, I came back and I was like, "Hey, I really want to work for you guys. Do you have a spot for me as an attorney?" And Ryan said, "No, I don't think that we really have a spot for you here. We're not looking to hire anybody." I said, okay, I understand. That's fine. So I started looking for jobs other places, but then I won the school closing argument competition with the mock trial group and Sach was one of the scorers for that. And so he saw me and then the next day walked into the little clerk's office I was in and hired me at that point. So been here ever since.

So it was meant to be is what it sounds like.

Yeah. A lot of dominoes really put into place, not by me to end up where I'm at.

I feel like similar situation too. I had no connections to any attorneys throughout my whole life. I didn't know a single lawyer. Go to law school, everybody else has these ties to get summer clerkships and all this other stuff. I was sending out letters to everybody, had no idea what I wanted to do. And through a bunch of happenstance, end up at a personal injury firm clerking, absolutely loved it. And the rest is history. And so I kind of feel like these things work out in mysterious ways and I'm thankful for you. It worked out well and for me as well. I think we want to pivot a little bit and talk about the trial that you just got your verdict in because do want to talk about big picture things as well for young lawyers and we want to get to that point so we have some more time to spend there.

But all right, so go ahead and acquaint our listeners with the facts of the case that you just recently tried.

Wait, Geoff, really quick. I want to ask, how many cases have you tried?

So as first chair?

Yeah, do first chair and then tell me second and third because I'm curious.

So this was just my second trial as first chair on this one.

Holy moly, congrats.

Thank you. And then I've been on about five or six with Sach as second chair. I've not been here for the full ride. And then we average about two trials a year, so I've been part of a bunch of them, but as far as being actually at counsel table, it's more limited as far as that goes.

Okay. So this is your second ever first chair trial.

Yeah, second time to be lead counsel.

The stage has been set in my brain.

Yes. And so this case is in Portland, Oregon against First Student. And so they are the world's largest private school bus company. And so what they do is they go around and contract with local school districts, say, "You pay us a contract fee and we'll provide your entire busing program. We'll provide the buses, we'll provide the drivers, we'll handle the routes, we'll pick up the kids," all that kind of stuff. And so it really is easy for school districts, especially smaller school districts to say, "Yeah, we'll contract with you. You can cover all the overhead." And then it gets divided up across the country. But they are giant. They've got facilities all across the US and Canada, and then they actually work some in Europe as well. This particular district that they were with was down in Southern Oregon. It was a smaller district of actually two different towns combined together.

And they had a driver who was taking medications that disqualify you from driving commercial motor vehicles. So they was on a hydrocodone and on a stimulant. And those two medications, you're not allowed to drive commercial vehicles with those. And so they had gotten, I think it was six different notifications along the way that, "Hey, this driver is taking these medications. There's no approval from a medical care provider for him to be driving while taking these. You need to do something here." They never did, kind of left him behind the wheel, and eventually he ended up causing a wreck.

And he's driving children?

Yeah, he's picking up children, taking them to school, taking them home. He'd been working for them for about a year and a half at this point whenever the wreck happened. And this was the last week of school before summer, so it was almost through another school year here. And he ended up causing the wreck. He just pulled out with no really reason why, no justification, pulled out from a one-way stop into oncoming traffic. And our client was headed from his left going about 45 miles an hour. And they had a, depending on who you ask, it was either a T-bone or a sideswipe where their corners hit. And then she ended up spinning and going off the road through a ditch, hitting a chain link fence on the other side of the road. Thankfully, there was nobody coming the other direction at the same time, or it could have been a lot worse for her.

Yeah. So this is not a tiny deviation. This is going the wrong way on a one-way street.

Well, he pulled out. So he pulled out from a stop sign to try to go the correct way, but pulled out in front of traffic. So she did not. It was one of those T junctions. And so she didn't have any sort of yield or stop sign or anything like that. And he was at a stop sign and just pulled out while she was driving. There's no obstruction of line of view. We don't really know why he pulled out. One of the weird things in the case was he was never deposed because he had. In Oregon, they have a weird privilege that all of your medical records and your communication with doctors have the same privilege as your communication with lawyers. And so we tried to get his medical records to say what else was going on with this guy other than what he reported to his DOT physical and got denied all the way to a motion to compel.

The judge said, no, you're not allowed to find out anything about this. And then the defense submitted an affidavit saying he was not healthy enough to sit for a deposition, and we just had to take their word for it where we weren't -

But he's healthy enough to drive a commercial vehicle?

Yeah. And so we never got to take his deposition, so we'd never even heard his side of the story as far as what happened, why he pulled out, anything like that. It was just strictly what was written in his file was the only statements that we got, and then what was on the police body cam footage. That's

What I was going to ask. Did he say anything to officers on the body cam at all about the wreck afterwards?

No, he was well-coached to not talk very much. First Student actually beat the police to the scene because their headquarters were only a half mile from, or their local headquarters were only a half mile from where the wreck happened. And so they were there with a corporate rep talking to the police on behalf of him before the police actually interviewed him.

Who did the driver call first? Did he call his company first or 911 first?

The company. He never called 911. Passerby had to call 911 before to get people to come. Wow. That was one of the-

They must have really beat that policy into him. You call us if you're in an accident.

We've had a couple cases like that too. It's the same thing. And the explanation they're giving is that's the way I was taught. They told us to call and I just do what I was told. But a couple questions. So y'all obviously are in Rogers, Arkansas. So how do you end up in Portland, Oregon on this sort of case?

We had fantastic local counsel, Mark Johnston of the Johnston Law Firm. He is a awesome trial lawyer with his office right there in the heart of Portland. It's actually like four blocks from the courthouse where he had the trial at. And he got the case and we'd worked with him before and done some good work. And so he called us and we teamed up on it and our team really melded with his whenever we were going into trial. So he was gracious enough to let me be lead counsel at trial, and he was awesome at handling all of the lay damage witnesses and the clients and did those sort of witnesses.

And I do want to get more into the trial itself, but before we get there, obviously cases don't just go to trial randomly. And in fact, more often than not, they don't. There has to be a reason why this case went to trial. I mean, the facts seem like liability is laid down, so I assume something with damages or maybe the valuation. Tell us why this case is going to trial.

I honestly believe it was the defense lawyer's decisions that they made as we were going through the case. Our firm has a policy of sharing as much information as we possibly can, as early as we possibly can with the insurance companies so that they have everything that they need to make their monetary evaluations. And so we send these clips from our focus grouping, clips from all of our different jury research. Sometimes we'll even do part of what we expect our opening statement's going to be and send that to them. We'll send them visual aids. We'll send them basically anything you can think of, little videos from our experts saying, "Here's what I'm going to say at trial," all those sorts of things and put it together. We started that process in this case because I could tell, number one, we do it in every case, but then I could tell there was a disconnect here between the value of what we saw and what defense saw in this case.

I started sending these different monetary reserve communications, and in response, I got a motion to compel all of our work product, which put everything to a halt for us sending information to the insurance company. The defense lawyer claimed that because we had shared stuff through negotiations, that meant all of our jury research had to be turned over and all of our work product was waived. We have waived that privilege for the rest of the case. Wild accusation that she though that, but that took, because of the way the Oregon system works, it took about six months for that motion to end up in front of a judge for us to have a hearing. She tried that about eight months before trial. We're two months out from trial and we finally get this ruling from the judge saying that that's a frivolous motion to compel. You absolutely do not have to turn over your work product.

And by that point, everyone's locked in to what their value is. I think they honestly believed our girl did not have a brain injury. And the only -

No, I was going to ask that. So what were her injuries that we can kind of understand? Because you're saying there's a different value that defense is putting on it versus y'all. What were her injuries so that we can kind of understand what that disconnect might have been possibly connected to?

Traumatic brain injury is by far her biggest issue that she had. The only other injuries that she had were muscular pulls and strains. And so those resolved within about two weeks or three weeks of the wreck. She still would have, like everybody does after if you've been in something like that, like, oh, it hurts to carry my shoulder, my purse on this shoulder, those sorts of things. But there was nothing actually seriously limiting her by the time that we got four years out from the wreck. From those, it was strictly the brain injury. And the defense just truly did not believe that her brain injury was real. They though that this was all psychosomatic.

But I'm going to go back a second because you sent me a write-up on the case, and so I think I have some more details than most people have. And one thing that stood out to me is talk about the difficulty of the case. I remember reading something that initially she didn't report any symptoms of a TBI or didn't say her head was hurting, nausea. And so my takeaway from that is, of course, the defense is going to say, "Ah, everybody automatically who's legitimate says everything that's wrong with them immediately." So tell us about that process, because I think in my mind, that was probably the sticking point for them.

Yes, 100%. She was on the police body cam footage telling the police she was fine. She declined an ambulance at the scene. When her mom took her a couple hours later to the ER, the only thing she told the ER doctor about was that her shoulder hurt where the seatbelt had been. And so her TBI issues did not kick in until later that night. She became nauseous. She threw up multiple times, started having headaches, all the classic signs of a brain injury. It was just a delayed onset for her symptomology. And then going through the case itself, her issues were getting progressively worse. And so she started with migraines that she was dealing with a couple times a week, and then six months later, it's now they're four to five times a week. And then six months later, she's having to drop out of classes at school because she can't leave her room.

And so it's this progression of symptoms that they say was backwards of what it was supposed to be. And so they called in neurologists and neuroradiologists and all these people to say, look at these scans. These scans don't show any brain injury. Look at her symptoms. This is the opposite of what they should be, because you're supposed to report all your symptoms right at the first and then they get better as you go on. That's the normal course for a brain injury. And so that's what they were fully bought into, was that these issues were not a brain injury or a legitimate one in their mind.

So the delay that they're complaining about, what was that, like 24 hours basically? Something like that?

Yeah, just under that.

Yeah. I mean, we've all had the cases where you're talking about somebody weeks later all of a sudden saying, but we're talking about a mere day, which I think in my belief is that's way understandable to a jury.

How old was she, Geoff?

She was 18 at the time of the wreck and 22 at trial. And so that was another issue is she's a very pretty little 18-year-old girl. And so she was a senior in high school and she looked like nothing was wrong with her in all the pictures and videos at the time of the wreck. She didn't have bruising, didn't have anything like that. And the next week she graduates from high school smiling in her graduation pictures, obviously, because that's what you do for a picture. But that was another hurdle, at least in our jury research showed we had to get over, was to convince people, yes, despite what you see on the outside, despite what she looks like, this young lady is actually very hurt in what she's dealing with. And so there was even contested issues where she had had, it was 10 months later when she had got her first brain MRI, and that did show damage to her frontal lobe.

They found a dead spot with the hemosiderin deposition stuff, blood in the brain basically is what that showed according to the treating radiologist. But the defense had a guy come in and say, no, that's actually this genetic malformation that doesn't actually show a brain injury there. So they had an answer to everything when it comes to our side of the case. Just thankfully, I think won the jury over was the super believable testimony from all of her friends and family. We even had her ex-boyfriend come in and testify. He hadn't talked to her in a year and a half since they broke up, but he was dating her during the time of the wreck and told about the changes in her from before and after, which was really powerful in my mind. And then also we had some really good experts who we got them down from the stand and they actually taught the jury about what was going on.

I'm

Going to take a step back before we kind of talk more about the trial though. Y'all do a lot of things to prepare for trials that I think are unique. I remember talking to Sach about this and talking to you about it a little bit. Can you walk the jury through the various ways you're focus grouping and testing this case way before you ever get to trial?

Yeah, so we started with focus grouping. In Oregon, you have to plead an amount of damages in your complaint and you have to have a justified reason for pleading that amount of damages. And so we started focus grouping this prior to even filing our complaint when we got involved in it so that we could say to the court, yes, Your Honor, we have a justified reason to believe non-economic damages are X, Y, Z in this case. And we could share if limited work product if needed basically from the judge. But Oregon has a lot of -

Can you ever change it? Can you change that number as discovery?

Yes, yes. But you have to get court permission every time.

Oh gosh.

And so that was one of the issues we had is whenever we were going through our testing, we were including punitive damages in everything that we did because in our mind, a company knowingly leaving a legally disqualified driver behind the wheel of a school bus is punitive. And so we had over a hundred million dollars in damages that we were putting in our complaint. Two weeks before trial, a judge disagrees with us, says, "No, that's not punitive." They dismisses punitive damages, opens the door to where defense then just admits liability. So all of the bad facts about this guy, all of his negligent training, all of his supervision stuff that they did, all that's gone. And so we don't have time to run new jury research at that point, but we do have, because we had been doing regular focus grouping, we did surveys, which you don't actually talk to people, but you submit out stuff electronically to them.

We did a big data study with the Campbell Group, and then we did actually closer to trial, we did real mock trial type stuff. And so we ended up testing it on over 600 jurors through all of it, but only the last round was the damages only stuff. And so we tried to use that as kind of a guide of what we ended up lowering our request to and then taking that into trial. It's so weird. The judge, when the jury is being seated, holds up the complaint and says, "In this case, you're going to hear the plaintiffs ask for X number of dollars," and then goes through. So I wasn't even the one who got to drop the bomb or whatever, talk about it in my opening. That came straight from the judge. And so it was a little awkward to go through some of that stuff, especially with the flip of the evidence there at the end where we're only talking about compensatory damages.

Did he say that before voir dire or after?

It was at the end of voir dire. So we had said, okay, yes, we agreed to the jury. And then whenever he's reading the statement of the case, that's whenever he put it in.

Could you inoculate the jury a little bit about asking for millions and stuff before he got to it, or were they completely cold at that point?

I did. In jury selection, we talked about who here could never be comfortable being on a jury that awarded tens of millions of dollars in damages, that sort of thing. I never went into the specific number with them. I just kept it kind of that vague tens of millions, tens of millions kind of a thing. And so that was the way that I was able to kind of brace them for like, "Hey, you're going to hear a really big number in a minute." So it ended up not being too bad. It was just a real new learning process for me.

Yeah, absolutely. That's one of those moments where I cringe a little. I'm like, "Ooh."

I wonder though if as far as anchoring damages, we try to bring it up as early as we can, and I think there are reasons in voir dire why you do that, right? You can cause a lot of people because there's just people who say, no matter what the facts or circumstances, I can never do that. But part of it too is you want to get them used to those bigger numbers, so it's not a shock. But I wonder if a judge saying it, if it makes it more digestible to a jury. In some ways - Or more

Authoritative. Exactly. It's coming from the judge. It's not attorneys arguing.

Yeah. In some ways, I wonder if they think, oh, well, that must be what these cases are worth. So maybe it was a helpful thing. I still would prefer to be the one to do it, but

Maybe, maybe, yeah.

Geoff, were you always going to be the one trying this case as first chair?

We had not made that decision up until about five months before trial. I had been working the case as lead trial lawyer, but then Sach was still planning on coming to Oregon until he got inducted into the inner circle. And so his induction was at the same time. He was like, "Geoff, you got it." And so Mark Johnston, like I said, he was graceful enough to say, "Yeah, sure, Geoff has got it." And we went up there and did it together.

So in doing all these focus groups and when you're standing up, was that you practicing or was it Sach or both or primarily you?

It was mostly me. I think he did some of the stuff at the very beginning with. Our jury consultant was Phillip Miller, and so he's worked with us on a bunch of different cases, but it was mostly me that was doing all the jury research, especially once we got to the. By the time we got to actually dress rehearsals, we knew it was going to be me at trial, so that was all me.

So how are y'all handling your dress rehearsals? Obviously this trial is, you said eight days, I think is what you told me. So you're not doing an eight-day dress rehearsal. So are y'all doing. Is it mainly opening? Are you just presenting the facts of the case and seeing. Walk us through that process, because I think everybody is generally familiar with what a focus group is. A lot of our listeners are familiar with what big data is. We've had the Campbells on, we've had Sean on. I know Sach has talked about it. We've talked about it ourselves. I don't think there's a lot of people doing dress rehearsals before trial. We've done full-blown mock trials, but we've never done a dress rehearsal. So can you tell us what that entails?

Yeah. Dress rehearsal for us is just jury selection and opening, and then we might go into one or two witnesses. That's it. We don't try to do anything close to the whole trial because that's going to be changing as things go. The only stuff that's really locked in, in my opinion, before trial starts is that jury selection and opening. So we'll do that, try to do it twice in two different days. So twice on one day, then edit in the middle, and then do it twice again on the day after that. We got the admission of liability so late here, only three days before trial started. We actually only got to do one round, and it was the Saturday before trial started, we were doing dress rehearsals. But we do try to do them now because we travel a lot for our trials because that's just part of our practice is we work with local attorneys, but we try to do it now in the venue where the trial's going to be so that you're adjusted to the time zone.

We have a policy where we have to start wearing suit and ties 30 days before the trial starts so that we're not pulling on our collar, because otherwise I'm so awkward in a tie. And so you got to get used to the "lawyer costume" is what I call it before you actually go to court. And so there's things like that that we do that just kind of get you in the mindset, get you where you need to be, and then that dress rehearsal is just literally the very last thing we do before pulling the trigger.

Let me ask logistically, as far as the dress rehearsal, because I've only ever heard that in theater, you know what I mean? Is the dress rehearsal, do you have other lawyers at your firm listening to you or is this mock jurors? Who is listening to you? Are they giving you feedback? Are you pausing in the middle of doing your opening or do you do it all the way through? Can you give us the logistics? I think a lot of people would like to implement something like this.

Yeah, we bring in mock jurors. Usually we try to keep it to around 20 for each round, and then I'll do a live jury selection where we go back and forth and actually go through all the questions, make them answer, all that kind of stuff that we're planning on doing. We don't kick anybody out of the room at that point, but we leave them all in. You're

Done, you don't get paid. Yeah, you're

Done. You're going home. We don't want you here. But after we do just this live jury selection, then I just go straight through my opening. Well, I'd say that we take a little break. Our jury consultant will talk to them like, okay, we're done with that. Take those notes that you've got, put them over here, and then we're going to go into opening, take a little five-minute break. And then I come back and just do my opening from start to finish. And then we'll have a debrief session where jury consultant is typically the one who does it. We'll meet with the mock jurors, say, "What was the best part? What was the worst part?" Have them fill out forms about all of their different feedback. "Was there anything in there that made you mad? That's one of the number one things that we want to say because I don't want to do anything that makes anybody mad in the very first day of trial.

And then is there anything in there that you said you really, really loved? This was really powerful in case we wanted to try to focus on it. And is there anything that you're confused about is a big one too. So that way we know going through, and that's why we try to have that day in between to edit and then do it again and make sure that we clarified all of the issues that the mock jurors had.

So it sounds like it's primarily focusing on your relaying of the information rather than issue spotting and all that, because you've already done your big data, you've already figured out what your themes are. It's just about honing it in terms of presentation. Is that fair?

100%. If we're learning something new at this point, we're in big trouble.

Yeah, exactly.

So this is really just am I saying it right is what we're looking for.

And is this through AH? Are they the ones who put this on?

No, we just do them internally with us and our jury consultant that we work with.

Okay. So he's able to get people in the venue where y'all are trying the case?

Yeah, he'll usually use staffing agencies, but that sort of thing.

Does it help with your confidence, Geoff, to be able to practice it in front of real live people?

Tremendously. Tremendously. Yeah. We'll do a couple of in-house practice rounds where it will literally just bring all the staff into our courtroom and say, "All right, Geoff's going to do jury selection on you today." And we'll spend a morning doing that. And that is helpful, but it's a lot different to be talking to Brenda, who I talk to every day whenever I'm doing jury selection compared to some person I've never seen before. And so that's doing the dry runs right before, literally as close as we can to the day of trial, in my opinion, is super helpful because then it's really just that rinse and repeat. And I'm like, "All right, I did this two days ago, going to do it again," kind of a feeling instead of being super, super nervous.

I think there's a huge message here to young lawyers on what you can do to feel confident when you go to trial, but having done something to different people, and you said two times a day, so you're having a couple rounds with a lot of different people, I mean, you feel like you've already tried this case. You go in front of a real jury, it's like this is the fifth time I've done it. I did this voir dire already. You perfect it along the way. That experience is invaluable. We had Sean Claggett on, I think it was last year, and they do their focus group Fridays at their office. And we're talking about the idea of what can you do if you don't have a trial setting, you're a young lawyer, you can't get trials because the reality is, I mean, you know how it is, some older lawyers have 200 jury trials.

I feel like that's impossible nowadays with the way cases get moved or they settle or whatever. So Sean brought up the point on the way they're doing their focus groups is the same to try to get their younger lawyers or even inexperienced lawyers more reps because you're going through the same motions. You should be doing this as close to trial as possible, meaning you shouldn't be doing an opening that you wouldn't go do in front of a real jury.

And the confidence of when you get in front of the judge and he says, "How long is your opening statement?" I'm like, "It is one hour and seven minutes, your honor." Then that sort of confidence is like, "Okay, yeah, I've done this before. It's going to be all right. That is really helpful."

If I was a defense lawyer, I'd be like, "Oh crap, he's got this down."

So we've talked about the preparation. So now you go to Portland, you try this case. Tell us about the trial.

Yeah, so Portland is a whole different world from Arkansas. I don't know if you knew that or not. I've heard. Yeah, it's a little bit of a

Different

Place. Don't

You mean our Kansas?

Yes, yes.

Yeah. It's night and day different, I would say.

Yes. And everything down to even just the culture that they use to approach work. And so this trial would've been a four-day trial in Arkansas because we would've ad everybody there at eight o'clock. We would've taken a 15 to 30 minute lunch and we would've gone till 6:00 and that's just how we do it and we're going to get this stuff done. Juries frequently there, they didn't have them show up till 9:30, and then they would take an hour and a half for lunch in the middle of the day, and then we had to be done before 5:00. And so we would get a couple of witnesses done. It's like, "All right, time for a lunch break. Everybody come back in an hour and a half." And I think part of that is actually due to their actual Portland employment law. They have to give long breaks and that sort of stuff for those things.

But anyway, it really made the case kind of drag as far as days go, but it made the days fly. We still did our method of the Joe Fried Speed trial, which was my expert witnesses, our neurologist, my direct exam of him was less than 30 minutes. And then our TBI education specialist, she was on the stand for 14 minutes as far as my direct goes. And so we did our witnesses as Quickly as we could to try to keep things fresh and interesting and short for the jury, not waste their time. But then it took eight days, eight trial days to do it. And then the jury took another whole trial day to deliberate, actually more than. And so it was a long time being there in trial. And my favorite visual or demonstrative that we used was this brain where obviously at this point, the whole case is does this young lady have a brain injury?

That's the question. And so we had our neurologist who was going through these scans that were done during her treatment and he came down from the stand and was standing in front of the jury. Their courtroom was set up where the witness box was on one wall and the jury was on the other. So there was probably 50 feet between where the witnesses sat and where the jury sat. And I didn't want him to try to do stuff that far away. So he got up and came down with me and we were standing maybe five feet in front of the jury box at this point. And I handed him this brain and said, "Just tell us where in her brain these injuries are." And he took it apart and there's little marks in here with Sharpie. And he went point by point and said, "You can see on this scan from this date where her frontal lobe has a dead spot up here at this point.

And then you can see on this scan from this date where this part, the hippocampus is shrunk on this side by 16%." And was literally marking it with a Sharpie. And then he just walked over and said, "And I'm supposed to give this to you now," and handed it to one of the jury members because I'd said it'd be great if we give it to the jury when we were prepping. And I said, "Wait, wait, wait, wait. We have to get permission from the judge to do this." And so I turned to the judge, said, "Your Honor, may we publish the demonstrative aid to the jury so they can see where he's been marking?" And the judge kind of sat there for a second and went, "Yeah, you can publish it, but you're not allowed to ask questions while they're looking at it." And I said, "Yes, Your Honor, we'll comply with that."

And so I just walked over, handed it to the first jury member. And then it was probably three or four minutes of complete silence while they passed it around and poked at the different parts and showed it to each other about where he'd been marking. And we're just standing there watching them examine this little brain. And that was, in my opinion, one of the most powerful testimony moments was when they were doing that. And you could really see lights click with some of these jury members as they were going through and actually applying, "Oh, this thing right here on this black and white picture that's been colorized and all this kind of stuff, that is here. I'm holding this young lady's brain, that's right here. Oh, okay, that makes sense now." And so that was one of the cool parts, I guess, for trial. Our trial judge was Judge Alexander up there in Portland.

Oregon's weird. They have a rotating judges on your case. So you start with a discovery judge, then you have a motions judge and a pretrial judge and a trial judge. And so our trial judge, Judge Alexander, was great and let us do basically whatever we wanted to do. We couldn't do a two by four timeline like our firm typically does because all of the liability facts got kicked out, but we had a two by four before and after where it was talking about her damages stuff that Jessica and our office made just a week before trial started. And so we anchored to that, anchored to the brain, had all of our visual aids. And it was the contrast between our side who was all demonstrative, all visual, all those sorts of things, and the defense side who was all language, words, just spoken words and technical stuff and trying to call in the most expensive doctors you can find to be their witnesses was kind of stark.

And so I was a little worried because the jury pool was very young and educated. Everyone on our jury had at least some college, all of them but two actually graduated the bachelor's degree. And the oldest person on our jury was like 55. So it was not what you would typically consider to be. It'd be a more sophisticated jury than you would typically expect. And so I was a little bit worried that the fancy credentials and the big words were going to win out from the defense side, but thankfully they went with us.

And I think you guys presented information in a way that we know is proven to resonate better with younger folks, which is know your audience. I mean, they're not going to retain information the old way. We're used to being on our phones, looking at reels, looking at PowerPoints, everything. And so y'all gave them the information in a way that they're going to retain. I guarantee you the three to four minutes of looking at that brain was the most exciting thing they had done in that trial and they're going to remember that testimony. Yeah,

That's what it felt like at least.

Geoff, that reminds me, my mom and I were trying a med mal case in a small county in Texas and our client, his leg had been amputated, so he had obviously a prosthetic. And so he took it off in front of the jury, handed it to me, and completely, genuinely, it was so heavy, I almost dropped it. And then he very innocently was like, "Oh, they can hold it too." And so I turned to the judge, I go, "Judge, can they hold it?" You know what I mean? And it got the jury very interested and had them understanding his day-to-day. So I could totally see how juries being able to touch, feel, interact with the trial demonstratives I think is really powerful and memorable.

Yeah. Sach talks to me all the time about the five senses. How can you engage the jury's five senses? What can you get them to do that will make them be part of the case here? And so that's the only way I could think of touch. What can I pass around that they can hold and touch and feel? And so it seemed to work at least.

Yeah, I mean, it sounds like it worked well. So you're finishing your eight days of trial. You said the jury deliberated for over a day, which has got to be the worst feeling in the world. I know waiting for those juries is awful and over a day is like killer. So tell us -

Yeah, it ended up being just over 10 hours total and they split it up between two days.

So what did the jury end up doing? We know what the verdict is. Tell us about it.

Yeah. So they only had one question to answer because of the admitted liability thing. There was literally, there was blanks for money. It's all that they had to do was the money. And the only question that we got during the entire 10 hours was what's the most we can give for future economics?

Don't you love that question?

And so we were like, okay. We though, okay, this is going to be a pretty good question. Now obviously I was asking for a lot more than what we got, but the defense suggested a lot less than what we got. So I think when you're sitting there for 10 hours and I spent this whole trial, you talked about confidence earlier. I spent this whole trial just trying to focus on humility instead of on building myself up. And there was this one verse from James chapter four that talks about you are but a mist, your life is here and then gone in a second. And so I wrote, you are a mist, at the top of all of my directs and all of my crosses. And so I'm sitting there for these 10 hours just thinking about, okay, what does this mean if they rule like this?

What does this mean if they write this number? What does it mean? And then realizing it's not, okay, I'm putting myself back into this. And so I just sit there and try to be selfless, try to think about anything except what they're going to do. We had to stay within 10 minutes of the courthouse the entire time. So a lot of sipping on coffee and talking to my kids and that was about it until we got the notice to come back in. So

What did y'all ask for and what did defense suggest? We

Asked for 65 million was our request on it. And then defense, they never said an actual number for theirs. The only actual number they gave was 75,000 for the economic loss. And then they said the non-economics is less than a million is what they said the total should be. But they've been spending the last eight days saying this girl's not hurt except for a deck injury that resolved within two weeks.

Why would the word million be in their mouth? I would not do that. To

Me, it seems like you're anchoring. Now you said somewhere between one and 65 million, right? Now

I will say, I don't know if y'all have read the book Nuclear Verdicts, but it's a defense oriented book. And that's what they tell them to do is if you are going to admit liability, make the amount that you suggest something that would actually be a reasonable verdict, low end of a reasonable verdict. And so I think - But

Not offensive.

Correct. Yeah, because I think if they had come in and said total verdict $75,000, that the jury would've just basically disregarded them and said, oh, well they're just being crazy. So I actually think that was one of the better things that the defense did was coming in and putting that anchor at a million because then it came in 5.3 or whatever. And so if you just look at this spread, it's closer to theirs than it was to ours. Thankfully, it was still high than all the offers and all that kind of stuff. So it was a good result, but I think that was probably the best move that the defense made.

I mean, it is interesting though because you have an admitted liability case, but if you're questioning whether somebody's hurt, I mean you've kind of put yourself in a bad position, right? You've admitted liability. You're saying some of her injuries for the day of were legitimate. She just doesn't have a TBI. And then you suggest a number close to a million, it almost seems like you're hedging. We're really not confident in our position. I think a jury can see through that. I mean, I've always thought that was an interesting approach. Fight hard during the trial and then when you come to closing argument, well, we're not at fault, but if we are, just give them less. It's hard to have it both ways. My

Rebuttal closing was nothing but is that accepting responsibility? He just stood up here and said they're accepting responsibility and then they're asking you to just discount everything that they did. It was like 30 seconds. That was the whole thing. So you're right. I think that the jury did see through that because they just sat there for a week and a half of trial days with you telling me this girl's not hurt and then all of a sudden you're going to try to say a million dollars. Now maybe you're trying to be reasonable all of a sudden, but it's- It's

Not consistent and doesn't fit with their story. Did you get to talk to the jurors afterwards? I

Did not. The judgment's not even finalized yet, and so we haven't reached out to anybody as far as that goes. I think it is technically allowed in Portland, but that's not something we typically do.

Yeah, 10-foot pole at all times.

We run after the jurors after. Really? They're trying to get out of there and we're like, wait, wait, we want to talk to you. Yeah.

Yeah. We always like to know what we did that worked, what didn't work, what stood out most to them. And it's always something you don't anticipate. It's just funny what jurors will really stick with.

Yeah. Some of the things you're worried about that you go and you talk to the jury and they're just really not as concerned, which is great that they have things like big data studies now because I think 10 years ago we wouldn't have known this. And now you probably have a decent idea before you ever step into the courtroom what people care about. You did have shadow jurors though, right?

Jury observers is what we had, but yes.

Okay. Jury observers. Yes, we

Did. Yeah, it was a shadow jury.

We've never done that before in one of ours. Do you think that's really helpful?

I think it is more helpful in a contested liability case, but even on this case, it was helpful because we knew by the end of our second witness, they're like, yeah, this girl has a brain injury. What are they talking about? So that was helpful to know, okay, I don't need to hammer as hard on these next three witnesses and that sort of thing. But it was a neat process where they would be sitting there watching everything going on, and then at the end of the day, they would dismiss the jury. Those folks would go back to a conference room with our jury consultant. And then by the time I got back to my hotel and changed and ready to work for the night, he was like, "Okay, let's debrief. I'll tell you what they said." And so we'd get to come in and as, "Oh, they really liked this witness.

They really liked this cross-exam. They really liked this direct. We need to do more of that, less of this," kind of thing. And it was 15 minutes at night. It was helpful and it was more of a, for me at least, more of a confidence boost than anything. I don't think I actually changed anything based on what the jury said. It was just, okay, yeah, that actually worked. Or okay, yeah, they don't hate me. Those sorts of things. Yeah,

I was going to say it's great that your jury consultant was kind of filtering it for you because not that they would say anything that would destroy your confidence, but I could see how it could make you a little more shaky if he's telling you feedback in a way that's not constructive if it's coming directly from someone rather than the jury consultant who knows what the goal is. And

They're not worried about hurting my feelings when they're talking to him too, so they can be a little bit more direct. Is

The deals with, you said trial observers, they don't know what side they're for, right? Yeah. And so they have no idea. We

Try for them to not know. By day two or three, they know just because we can't help but interact with our jury consultant because it's like, do I need to do anything else? And so they see that, but whenever they're hired, they're not told. So at least for the first couple days, it should be as unfiltered as you can get. So

I want to talk to you about this and then I want to move on to some of these bigger picture questions we have following your trial. But what do you think, if you could sum up a couple things that you think worked really well and maybe one or two things you think you would change in the future, what would those be?

So I think the things I would change in the future would be our motion practice, number one, because this is a punitive damages case, then it's an entirely different trial and an entirely different thing that we're dealing with. So I think that's obviously the big issue with this case was losing punitive damages and letting them admit liability. As far as the trial itself goes, I think that I did get a little bit too reliant on experts at points where I was like, oh, our expert says X, Y, Z about this scan and this expert is talking about where this class was dropped and those sorts of things. So I would probably be a little bit less focused on that and a little bit more into the story of the people that knew her before and after. That's why I was so thankful for Mark Johnston because he did do a really good job of telling these stories from these college kids.

But as far as something we did good, I think it was we really fought hard not to let defense frame the case. And so they would come in and take a visual that we'd used or something and they would try to basically just directly rebut all our points. And so in my mind, I'm sitting there and I'm watching them. They've got the visual aid summary of my expert's conclusions sitting on the TV screen for the entire time they're talking to their expert. It's like, I love that. I'd love for the jury to be looking at our expert and everything that they said while their expert's talking. What I did not want to do was give that back to them and come in and say, oh, well they said this, here's the truth. They said this, here's the truth. They said this, here's the truth. And really reframe because there was no direct open lies.

They've been openly lying, sure, but they were just arguing. And so I didn't want to try to rebut every single point they made because I think that's a trap that we fall into is because we have a rebuttal for everything that they're saying and we think, oh, we can argue that back. We can argue that back. Especially as you get close to closing and you're getting to this point where they're making their summary of how they saw the case and it can be really easy to just go too long and focus on what they said. So I do think we did a good job staying on point on what we wanted to talk about and not really letting them reframe what the case was about. I

Think that's interesting because for us, every time we've talked to jurors after a case, it's never, I wish y'all would've spent more time with this expert. I wish you would've explained this more. I'm really glad you rebutted every point we've already heard you make. It's always like, y'all did too much. You could have been out of there a couple days earlier. I think Joe Fried's speed trial is spot on. Let's make this as simple as possible. I know he's not the only one who says that, but I think jurors understand it quicker than what we give them credit for. And they haven't lived the case for four years. They have a limited amount of time. I mean, our attention span now is very short. So it's like you just give them the basics, let them figure it out. But it sounds like you did that.

You didn't fall into the defense's trap, which is let's make this as confusing as possible.

Yeah, I tried to at least. And then there's this whole concept of positive repetition versus despicable repetition. And so we tried to use the positive repetition of here's a visual that says what we want to say, here's our expert saying it, and then here's a demonstrative, whatever it is, three different ways of conveying the message. But then that was it. We didn't go back with every expert and say the same thing or go and ask the same questions on every cross and those sorts of things where the jury's like, oh, well, they're just doing their routine. I do think that we have to be careful. It's good to have multiple methodologies of conveying messages, but just don't get too stuck in that.

Eleanor and I talk about something all the time, dealing with imposter syndrome. We work with Charla, who's also an inner circle with . All three of us work for fantastic trial lawyers. I think it's easy to feel like you're not ready or easy to be the number two, but it's hard to be the number one. How do you deal with that feeling or how do you get past that imposter syndrome? For

Me, it is actually the opposite of what you would think. It's removing myself from it, where I actually run into more of an ego issue than anything where I'm like, why am I not doing that? I've always been like the, give me the ball coach, let me do it, kind of a guy. And so whenever I get into that point, that's whenever I find myself stumbling and falling and doing bad things and getting bad results in cases. But whenever I remove myself from it and I'm like, what is best for the clients? Where are we going with this? And that is where my confidence comes from is knowing, okay, I'm not making this about me. I'm not making this about my career, about my name, anything like that. This is more about literally what is the best thing for the client and in my personal life, how can I best follow what I think God wants me to do?

And when I do that and then I take it to this level of just being knowing there is no firm in the world that would be more prepared than we were whenever we went to trial. You take those two things and put it together, approach it with humility and overwork it, and it's almost impossible to not have some sense of confidence when you're going in there. Did

It help having your local counsel there with you? It sounds like he's very experienced, so having someone to tell you you're on the right track or in the guardrails or was that not really something that helped or what was your feelings with that? Yeah,

He was great. We had the weekend in the middle of the trial and our whole trial team went over to his house and had dinner with him and his wife, and it was a good bonding type of thing. And he was right there with me in the trenches together. Ryan Scott from our office, he's been with Sach since basically day one. He was also there. He handles more of our appellate stuff, and so he was giving encouragement from him. "You're doing great. This exactly how you're supposed to be doing it." Checking all the boxes, all that kind of stuff was very helpful. So having the team there behind you and supporting you and saying, "Okay, yes, you're doing everything that you're supposed to be doing," was for sure very helpful. I think if I had tried to go into there and there was nobody sitting in those seats behind me, that would've been a different experience for sure.

Yeah,

You need the cheerleaders for sure. Yeah.

That's

Awesome. So it sounds like there's a lot of things you do to build your confidence. Like you said, you lead with humility, you take the ego out of it. It sounds like doing these mock focus groups is really beneficial to getting up and doing it. Are there other things that you and your firm do to help build that confidence and to feel prepared to go to trial? It

Comes back to, I guess our depositions, our trial methodology. I knew what the points were going to be that I was making at trial whenever we took the corporate rep deposition. Now, obviously some of those got kicked out because of the whole rulings and everything, but as far as the damages model goes, we knew what that was a year before we were at trial. So there's no questioning of have we done everything? Have we checked all the boxes, covered all the bases? And so I think just knowing, okay, yeah, we've done everything that we could possibly do to get there is very helpful, especially whenever you're doing it months and months in advance and you're going and taking a deposition and like, yeah, this is it. This is the trial direct of this expert. It's done. I

Always feel like the fear of trying a case, part of it's inexperience if you haven't tried a lot of cases, obviously there's going to be the unknown there, the confidence won't be there, but the one thing we control is what? How well you prepare.You're scared, but you're prepared really, really well for that trial. I feel like you're going to get in there and eventually you're going to be more confident. I always tell people, I don't always tell people, but I think one thing Eleanor and I were talking about, well, what do you do if you're a young lawyer and you're scared? Well, you prepare, right? You learn the case better than your opponent and you do the things like the focus groups, the mock trials, so that you're getting your nerves out of the way before you ever step foot in the courtroom. Because if it's the first time you've ever tried a case, the first time you're doing anything is when you're in the courtroom, you've already lost that case.

I mean, you should be testing this stuff six months, a year before you ever go to trial, especially on a big case. You don't want to think you have a big case and go to find out, well, if I would've focus grouped this a year ago, they would've told me it's a $0 case. So that's something we talk about is being as prepared as possible and that takes the nerves away and I think that takes the fear away as well. So

One more thing on that. I think just accept that you're going to be nervous. It's okay to be nervous. I was wearing my little WHOOP band whenever I was in there and it said I had high stress day. Every single day my heart rate was elevated, my palms were sweaty. That's just part of it. If you're not nervous, then I don't think that you are. If you're not doing things in your ordinary life that make you nervous, then you're in too much of a comfort box, in my opinion. And so I think that's just do more things that make you nervous and get used to that feeling and then it'll be better. I

Also think if you're overly confident and you're not nervous, you're probably not going to be doing the things you need to do to prepare for trial. Those nerves, overcoming those nerves make you do the things that are going to make you more prepared. Anyway, just one other question real quick. If you had to give any advice to young lawyers or people out there who haven't tried a lot of cases, what would you tell them? Find

A mentor. And if you can find a mentor who you actually work with in your firm, that's fantastic. If you can't, find one from somebody else that's around and go and watch what they do. Watch the trials. Sometimes just go sit at the courthouse. Now, I know a lot of times these days you're not going to learn anything if you just go sit at the courthouse because it's going to be uncontested divorce hearing after uncontested divorce hearing. But if you can get an actual trial schedule, reach out to those lawyers who are on it like, "Hey, is this going to go to trial? I want to come watch an opening. I want to come watch a direct." And just go and watch from people, send emails, go knock on doors, say, "Hey, can I take you to lunch? Can I learn from you?" Type of a deal.

And then read books. There's so many excellent trial books about all the different ways to do it, all the different mental approaches to it, but don't read just trial books. Read stuff about becoming a better person, becoming a more whole person, being fully integrated into who you are so that you can really accept, okay, this is me and you're authentic whenever you're standing in front of a jury because that's the number one thing is that you are you. I told you this was my second trial. My first one was a defense verdict because I stood up and I tried to be Sach Oliver, and I'm not Sach Oliver. He's a foot taller than me and the size of a refrigerator and a real true cowboy. I'm the opposite of that. Figuring out who you are and just being comfortable in your own skin and just being authentic is I think the number one thing you can learn to do.

And you can only do that through self-development and this self journey of figuring that out. And so find a mentor and then take what they say, apply it to who you are, figure out who it is that you are as a lawyer, as a person, and then just go be that. And

If that doesn't help, go talk to Geoff.

Yeah, exactly. The guru. I'll

Take you to lunch.

Yeah, exactly. We really have loved having you on the podcast and I've just loved hearing your experience and your advice. It's always helpful for us and for our listeners. Thank you.

Congrats once again to you and your clients. Terrific work. And if anyone needs anything in Arkansas, definitely talk to Geoff or Sach. They are the best. So thank you, man. We appreciate it. Thanks,

Y'all. Appreciate it.

I think you can tell, and we at Aldous Law here, we actually kind of like each other and we absolutely love, love what we do. And we work a lot of our cases up from the get-go, but we're brought in on cases a lot. We try cases all across the nation. If you have a case that you're interested in talking to us about, we'd love to hear from you. We've tried everything from trucking, workplace injuries, explosions, and burn cases, dram shops, rideshare sexual assaults, birth injury, your personal injury cases. If you need a partner to help you with your case, please call us. We can be contacted at Aldouslaw.com. We'd love to hear from you.

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