Judges keep shrinking the time lawyers get for voir dire, which means the old question-by-question march around the jury array no longer fits. Peter Koclanes, a Venable partner in Denver who tries securities, class action, and complex business disputes, joins host Kevin Morrison to walk through three tips drawn from more than 35 years of practice: discovery, jury selection, and examination. Peter explains why he personally divides up boxes of emails, why setting the outline aside and listening to the answer beats marching through a deposition script, and how a hypothetical about two opinionated neighbors, John and Jane, reveals how an array thinks. Tune in for his case for trying fewer claims with fewer witnesses.

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Great trial lawyers are made, not

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Welcome to another episode

of Verdict Academy,

where we bring you the best trial

lawyers in the country to share their top

three trial tips. My name's Kevin

Morrison I'm in San Francisco.

And today I'm pleased to have Peter

Koclanes join us as our guest.

Peter is a partner at Venable's Denver

office where he tries important business

disputes, securities

cases, class action cases,

and other complex civil matters.

Peter's one of the top trial

lawyers in the country,

according to his opponents and the

judges who have seen him in action.

He's a member of the Invitation Only

International Academy of Trial Lawyers,

and is described by both his peers

and opponents as intelligent,

methodical, innovative, thoughtful,

built to be a trial lawyer.

In addition to practicing for over

35 years at the highest level,

Peter's been a leader in his

community and for example,

has served as the president of a

Colorado Trial Lawyer Association and has

chaired the Colorado Judicial Institute.

Peter,

welcome to Verdict Academy.

Thanks so much, Kevin.

I'm glad to be here.

I'm super pumped to have you on, my

friend. We've got the three trial tips.

We'll talk about that in a second, but

just as a kind of general background,

what drew you to become

a courtroom lawyer?

Interesting question, Kevin. I

always wanted to be a trial lawyer.

I grew up playing sports,

very team-oriented.

I played pretty much every

kind of sport there was.

My wife didn't know me at the time

would characterize me as a jock,

one of those jocks. And I just love

working with teams and competing,

and it really has stuck with me.

So from the time I was

probably in elementary school,

I wanted to be a trial lawyer.

Wow. There's a massive overlap in my

view between competition and trial.

Many of the best trial lawyers are,

all of them are competitive

and most are athletic.

Was there something about the law,

like you saw a TV show or you

got lawyers in your family,

or what was it about like, oh,

a trial lawyer as opposed to

competing in some other area?

Well, I'm going to date myself here. So

I don't have any lawyers in the family.

An uncle who was trained as a lawyer

and he does transactional work.

No trial lawyers. My daughter's on

her way to becoming a trial lawyer,

and my wife's a trial lawyer. But

prior to that, no trial lawyers.

I have to tell you, Perry Mason had

a big impact on me back in the '60s.

Yeah.

So I'm dating myself. It's

also helping people, Kevin.

I just get a thrill out of being able to

help someone who otherwise wouldn't be

able to get it.

And the law and our judicial system

provides all of us an avenue to

resolve disputes.

And most of our clients are in

positions where but for that system and

but for having an advocate

really fight for them,

they're not going to at least have

the opportunity to get justice,

much less get it at the end.

Yeah, for sure. And we got

a great. Everybody complains

about our legal system,

but compared to every other legal system,

I think we got the best in the world and

we still got the rule of law here that

our clients can depend on. So

awesome. So let's get into it.

The three tips you want to provide

generally relate to discovery,

both documents and depositions.

That's the first point.

The second is jury selection and

the challenges of limited time.

And the third is examination,

both direct and cross.

So those are the three main points.

So let's start with point number one,

discovery, documents.

You got big complicated

cases above my pay grade.

You're probably swimming

in megabytes of documents.

Talk to me about document

discovery, Peter, the case to trial.

Definitely. So I'm a business trial

lawyer. That's all I've ever done.

So you're right, exactly right.

A lot of my cases will have

huge volumes of documents.

And I've seen a lot of different practices

and a lot of different way people

handle this.

I started practicing after clerking

for a judge for a few years

up in New York at a

large Wall Street firm,

and we had gigantic document cases.

And that was back in the '90s

before all of these databases

and everything else.

And back then there were teams

of associates that spent most of

all their time reviewing documents

and analyzing documents and the like.

Things have changed a lot since then

with databases and intelligent searching,

and now AI is even

changing that even more.

But at core and business cases, it

really does come down to the documents.

And documents are my

friend in these cases,

even though there's a lot of them.

So the tips I really focus on are

in discovery, document

discovery and depositions.

And in document discovery that

the mantra is prepare, prepare,

prepare for document discovery.

When we started even at the beginning of

the case, all the way through the case,

we're thinking about how

we're going to try this case.

And documents are obviously

a huge part of that.

So even beginning with the complaint,

what we'll do is draft a complaint and

make sure we include specific allegations

on issues where we are going to want

either document or deposition discovery.

And so we intentionally do

that because we know later on,

if we get into fights about

relevance or discoverability or

proportionality and all

those kinds of things,

we want to have a place that we could

point to in the complaint where we've got

a basis to seek that. And we'll

do that all throughout the case,

but that's just starting at the beginning

of the case and really teeing up

document discovery. One of the judges I

clerked from that court of appeals for

the Federal Circuit in Washington was a

pretty terrific trial lawyer in his day.

And he used to tell me, Peter,

the key to winning trials is know the

facts of your case better than anyone

else. And it's a pretty easy thing to

say, but it's a harder thing to do.

But I've really tried to do that. It

takes a lot of work. And so in our cases,

I make sure that I,

along with the other folks who

are going to be trying the case,

are actually personally reviewing

the documents so they know the facts.

And in our cases, a lot of

them are business tort cases,

which I know you do a lot of torts

and injury torts and the like,

and business torts are no different.

And a lot of times it's piecing

together a document from over here and a

document from over there. And then

in the middle you get some deposition

testimony and you put together

the story based upon that.

And so you really need to know

the documents in these cases.

And we use modern database

analytics to cull down documents.

This recent case we had for a

client out in LA who had a large

arbitration pending in Colorado,

there were three million

pages of documents produced.

And so we had to use this data analytics

program to help cull that down.

But at the end of the

day, my partner and I,

Nick DeWeese and I sat down and

we divided up 36 boxes of emails.

And he took the first half and I took

the second half, and that's what we did.

We spent a good amount of time

over the holidays last December,

each of us going through these things,

but we found gold and it really helped

get that case resolved about a month

before trial.

So documents are your friend.

Don't shy away from reviewing documents.

Roll up your sleeves and get into it.

And just like Nike says,

sometimes you just have to just do it

when it comes to document review and

putting that together.

Wow.

What a great story to distill

three million pieces of

information to try to distill that

because at the end of the day,

you've got a big rule of three guys,

kind of comes down to three things

or three documents. Generally,

that's kind of my go-to. Maybe

it's one more, maybe it's one less,

but I like to make it about three things.

Got to keep it simple. And to distill,

it takes an extraordinary

amount of work, Peter,

for you and your team to distill

that volume of information down to

three. And for you to personally

take 12 boxes or whatever it was,

just gobs of pieces of paper. It's

not glamorous. It's not exciting.

It's not closing argument, but

that's how you win your trial.

Find that piece of that one email

that gets your case for you.

That's how you do it.

Yeah. Well, I know you do

that in your practice, Kevin,

and your cases may not

have three million pages,

but the documents in your cases

are as are more important.

And I know you get into those things

and study every line and every page and

really take some complicated component

of the documents and distill it down into

something that's simple. And I love

the rule of threes, by the way.

Unfortunately,

I think our daughter who's in law school

right now grew up hearing that from me

in terms of she would talk

to my wife Jean and me about

presentations at school.

And it's like, Caroline,

you got to distill it down

to the rule of threes.

Yep. It goes back to our DNA, I

think. Father, Son, Holy Spirit,

whatever it is.

Let's tell you three things and it's

just we're wired to live for three things

and it just makes it easy

and your attention spans

there for sure. So hard work,

the key to documents. Depositions, Peter,

talk to me about deposition practice.

Depositions, unfortunately,

some lawyers overlook the opportunities

that are presented in depositions.

And again, the rule of three depositions,

it's easy. It's listen, listen,

listen. So many of us,

and we're busy and we are not just

working on one case at a time.

And so a lot of us will rely on younger

lawyers to put together outlines or

pull documents as potential

deposition exhibits.

And that might be okay as a start

for a first draft and the like,

but the person who's taken the deposition,

a lawyer who's taking the deposition

really needs to get into this stuff and

come up with sort of this

approach, a holistic approach,

how they're going to approach the witness,

figure out what documents they may use.

And sometimes I have a whole bunch of

exhibits I don't use because I don't know

what the witness is going to say,

but I want to be prepared to go down

whatever route that the witness goes. And

as far as outlines,

I have kind of a mini outlines and

I might outline things on particular

potential exhibits. But even then,

there's some folks who are really good

trial lawyers who will have a detailed

outline.

But the problem with having too much of

an outline is a lot of us rely so much

on the outline, we're not

listening to what the witness says.

It's critical when you ask a question

to me is to listen because if you

don't and you're just tied to your

outline, you might hear part of an answer,

but you're so tied to your outline,

you don't follow up on that and

you go to the next question,

you blow an opportunity. So if you

use an outline, ask your questions,

put the outline aside,

and then go back to it when you're ready

to go onto the next subject matter or

whatnot.

Another thing in depositions,

and I anticipate you do the

same thing, is so many lawyers,

they get really great deposition testimony

and then they go in and they ask the

last question. And you know

what I'm talking about.

But when you get some good

answers, leave them alone.

When you get the good

answers, just move on.

No matter how tempting it is to

ask that next question about, okay,

and so you admit you were

negligent. Don't ask that question.

Get the great testimony and

just move on. Obviously,

stating the obvious,

using depositions as an opportunity

to learn and nail down the witness

about unknown facts is really

important. But what we do,

and I'm sure you do the same thing, Kevin,

because I just know what

kind of lawyer you are,

is use the opportunity of these

depositions as an opportunity to

set up potential impeachment of a witness

at trial. And there's so many times

when I might be in there

taking a deposition and I'll

have a colleague in there

with me or a client in there with

me when I'm taking opposing party's

deposition.

And I'll ask them questions and I'll

get the answers and we'll take a break.

And we'll go out and do a breakout room

and the client or my colleague will say,

"Well,

what were you trying to get at with those

questions and those answers that you

got?" And I said,

"They were great answers because I've

got these documents that completely

refute what that witness has

said." And then they say, "Well,

why didn't you show them that

at the deposition?" And I said,

"I'm going to wait for trial to do

that." But it's just judgment calls.

And so really use these depositions

as an opportunity to set up

impeachment at trial.

It makes trial prep so much easier.

It makes the trial so much easier.

And it's going to lead to success

because you've got that great deposition

testimony in the can. It's not going

to change. At least in Colorado,

it's 30 days to review a fine. Even

if they change something in it,

you still have the opportunity

to question them about it.

So don't just go in there thinking

about this as an opportunity to find out

about unknown facts. Really

use it as, and a lot of times,

depending on the size of the case

and the importance of the witness,

I'll use it almost like I'm prepping

for cross-examination at trial and just

have everything lined up and nail and

get that deposition testimony in the can.

Yeah, I can agree with you

more on a couple issues.

Just want to highlight the listening part.

I think that takes some degree

of confidence and experience too.

And I was a younger lawyer and I just

didn't trust myself to, I'd forget,

you're so in your head initially, right?

You're just in your head and you

don't want to forget anything.

Just tie to your outline and, oh God,

did I ask that guy that question?

I could make sure I asked that one.

And so you're so in your head

that you forget to listen

to the answers. And the

answers, they can be nuanced.

There can be a pause. There

can be a non-answer answer,

which can be really helpful. And

so it's so important to listen.

I think it does take some degree of

confidence and experience to get there.

So important. And the deposition stuff,

leave the good stuff for trial.

I can't agree with the more,

especially in the experts. The

experts, I would call them name rank,

serial number depths.

Give me all your opinions.

Let's save the good stuff for trial and

just everything, everything, everything.

Now,

there are times when you want to settle

a case and for some reason to nail an

expert on certain things.

So you might use some of your

good stuff because of that reason.

But generally my rule is I'm

setting this case up for trial,

see if you're good stuff for trial

and just ask the open-ended questions.

And one of my favorite

questions in deposition is why.

Because why just calls

for a huge narrative and

hopefully there'll be gold in

that narrative that you

can use later. So yeah.

Right. No, I love that. I love it.

Great strategy. Great strategy.

Yeah. Well, same as yours.

All right, jury selection.

I'm guessing the vast majority of

your work is federal court stuff.

Is that fair?

Not necessarily. No. Okay out

in Colorado as a plaintiff,

I really enjoy the state courts.

I think things tend to move a little

faster out here in state court. Okay.

But sometimes we're in

federal court as well.

But in terms of jury

selection and voir dire,

and I don't know what you're

seeing out in California,

I know you practice all over the country,

but what we're seeing in Colorado and

some other jurisdictions where I try cases

is the judges are really limiting the

amount of time that they're providing

for attorneys to do their

voir dire and jury selection.

And out here,

at least there's a number of federal

court judges that want to do most of it

themselves. And so the issue there is

to be super strategic in my opinion.

Jury selection is so doggone

important. It just is.

I think it's the case.

And I have a joke when I sit down when

jury selection's done and they're sworn,

I just turn to my whoever

I'm trying on the case. Okay,

cases oversee at closing because I

think it's done at jury selection,

but go ahead. Sorry.

Well, I know you do the same thing,

but boy, prepare, prepare, prepare,

and then listen, listen, listen.

And what I've started to do,

particularly given the limited amount

of time that we have to do this,

is back in the old days, I would

have my list of questions and topics,

and I'd kind of go around the array

and I'd ask people different things and

really look at them and

ask them about something.

And what I found is that

takes a lot of time.

And we really don't have time to

do those kinds of things anymore.

At least where I practice, we don't.

So what I'll do is actually try to

create a conversation with the array,

and I'll set up hypothetical

binary position. So I'll say,

ladies and gentlemen,

I've got a neighbor John

who lives to my left.

And this is a contract case, Kevin.

Say, "My neighbor John,

when it comes to contracts,

it has got to be in writing and it's

got to be signed by both parties.

And if you don't have that,

you're out of luck." And then

on the other side is Jane.

And Jane's a real bright person

too. And when it comes to contracts,

her view is a person's word is

their bond. That's all you need.

And then once I set that up,

I'll say, "Ladies and gentlemen,

how many of you are more

like-minded with John?

Raise your hand." And then I can

kind of get a sense and I'll say,

"How many of you are more like-minded

with Jane?" And I get a sense.

And so you just start on these

bigger case issues. Pretty quickly,

you can start to get a sense

of who's thinking what.

And then I start kind of focusing in

on particular jurors. And I'll say,

Ms. Smith, you had mentioned that you

are more like John. Can you tell me why?

And then everyone gets to hear it.

So you're kind of educating

the jury at the same time,

but you're also eliciting a whole

bunch of information about the way they

philosophically look at things. And it's

not just, do you believe in contracts?

But it kind of it. And

I do that same thing,

whether it's a contract case or a fraud

case, misrepresentations or omissions.

With a fraud case, I might

say, "My neighbor John,

he believes don't trust anybody.

You need to verify everything.

If you trust somebody, that's your

own fault." And then I'll say,

ever heard the old saying, "Fool me

once, shame on you, fool me twice,

shame on me." John doesn't believe that.

He thinks if you get

fooled the first time,

that's your fault.

And then I go over to Jane and I say,

"Jane's view is that people should

be honest and tell the truth.

And when they start to tell the truth,

they should tell all the truth." And

then I'll try to set up that dynamic too.

And then I start asking the

array, "Are you more like John?

Are you more like Jane?" And start

nailing and focusing in on that.

The other thing is, just

like in depositions,

don't stick to your script. Listen,

because you will hear some

amazing things. And when you do,

you don't want to just move on. You

want to focus on that. So again,

and to your point about jury selection,

so again, one of my partners,

Nick DeWeese and I tried a

week-long trial in a pretty hotly

contested business torts

case. Nick did the voir dire,

and he's a younger lawyer.

Well, everyone's younger than me, Kevin,

but he's younger.

I'm right with you, my friends.

But he did the voir dire. And really,

it was a top 10 Colorado jury verdict

that year that we got for our client.

And so we posted on the Colorado

Trial Lawyers Association Listserv,

just like you do with your wins.

And somebody wrote in and responded,

one of the members saying,

"Can you have whoever did

the voir dire give me a call?

Because that's what wins the case."

So call her up and tell her what a

great job he did and how he did it,

but it's such an important

part of the trial.

For sure. When you're with limited

time, the method that you said,

do you agree with John or you

agree with Anne or whoever?

And then you can loop everybody in how

many you lose with him and how many agree

with her?

And then hopefully the judge will see

that you're actually making progress and

doing a good job on voir dire.

I'll give you some more time.

I think that a lot of judges think that

lawyer do a terrible job of voir dire,

and I think many do. And

so I think they limit it.

I kind of throw the baby out

with a bath water and say, okay,

you're getting 15 minutes because

everybody else I see is not good at this.

And once they see that you're doing

effective voir dire, they tend usually.

Not all. They're federal

judges, right? But not all.

Some will give you more time if you're

making progress and actually getting real

answers that are case determinative,

frankly. What's your status on

questionnaires? You like questionnaires?

You don't like questionnaires?

It depends. This is a couple years

ago I had a business torts case.

It was a corporate governance dispute

among three guys who started a cannabis

business out here. And it was

on the defense side for that.

We had counterclaims. But there were

a lot of technical issues in that,

also just concepts.

And so having that questionnaire

really saved a lot of time, Kevin.

But we worked really hard with

plaintiff's counsel to develop a fair

questionnaire. And the

judge, terrific judge,

was very receptive because we were

able to work together and come up with

an agreed upon approach to use it.

And it was super, super helpful.

Yeah.

My philosophy on those is people

are generally more honest,

open when they're by themselves writing

down their thoughts about certain

case-specific issues. When

they walk into open court,

it's such a weird experience. It's overly

formal. It's stuffy. They're nervous.

They don't want to talk

in front of people.

They'll answer however it'll

shut the question down,

just say yes or no so

you stop talking to me.

So I think people are more

open on questionnaires than

they are in open court.

And so I'm a big fan

because of that reason.

And hopefully you can get agreement

with the other side and that makes the

judge's life easier. All right, our

third and final topic, examination,

both direct and cross. What are

your tips for direct exam, Peter?

Again, both on direct and on cross,

to me, less is more. I'll tell you,

and this was back in my career.

And just like we all are,

we're sponges and we just listen

to other lawyers and learn.

And a pretty successful injury

lawyer out of Boulder taught me this,

which is don't put on more testimony

and evidence than you need to win

and prove your claims. That's number one.

And number two is don't

include more claims for trial

than you need in order for

your client to win and recover

the appropriate amount of damages.

And I've always think about that. And

you've kind of said it early on in this,

Kevin, which is simplify

things. Keep it simple,

focus on what's important and get it done.

And that's my approach for direct

and that's my approach for cross.

Further corollary is you don't

need to call multiple witnesses to

make your point. And I know you've said

it before because I've heard you say it

before, that you don't need multiple

witnesses saying the same thing. In fact,

it takes away from the jury's

view of your client's case when

you do that because it's kind

of like, what's going on here?

So I agree 110% with your viewpoint

on that, and it's so important.

Lastly, the focus is on the witness

on direct. It's not on the lawyer.

And so many lawyers are up there

waving their arms and it's like,

what are you doing? It's direct.

It's all about the witness.

And if the witness is your client,

you want the jury to be focused on your

client and your client telling their

story in their own words.

And that's the most impactful thing that

you can possibly do as a trial lawyer

on direct is let the witness tell the

story. Now that means there's a lot of

preparation for that, a lot of prep.

And make sure you spend the time doing

that. So many lawyers are so focused on,

well,

I want to nail them on cross if they

spend all this time on preparing for cross

and they don't prepare for direct of

their client or other important witnesses.

And then just anecdotally,

the one thing I would say is going

back to the number of witnesses is

some of my best jury verdicts on

our side as a plaintiff has been

our client,

maybe an important non-party

witness and an expert or two.

And then the defense goes up

and puts on 12 or 15 witnesses.

I think I can't tell you exactly

what the jury's thinking.

I can just talk about the results, but

I've had pretty good results doing that.

And again, it goes back to what you said,

which is keep things simple and present

it in a way that the jury understands

it.

No, it's so important. There's so many

pieces of gold in what you said, Peter.

The whole, why call three witnesses

on something when one will prove it?

And that's even backed up

by a study I read somewhere.

And I keep freaking this put in the

show notes, but they did a big study.

They researched this. If there's a red

light, green light case, for example,

and plaintiff calls one witness, the

light was red, boom, you prove it.

But now I got two other guys

who said the light was red too.

So now you're calling three

witnesses, the light's red.

And you actually are going to get a worse

result with more witnesses because I

think basically the

people are thinking, well,

why is he trying so hard to prove

this? It's just so weird. I mean,

we know it's red.

Why do you need to call three people

on that? They get really suspicious and

start going these rabbit holes. So

less is more for sure. And like, oh,

I'm going to call three physical

therapists. Really? Why? Why not call one?

Or maybe the doctor can talk

about the therapy. I don't know.

But it's hard because I think

law school, the more, more, more,

want to build everything up and you

got to get no distill less is more.

So absolutely. And the plaintiff

direct exam, my God, it's so important.

And it's got to be they've got

to tell their story, but man,

it takes a ton of time. It reminds that

letter, sorry, the letter's too long.

I didn't have enough time

to write you a short one.

It takes so much time to prepare

to keep it short and simple.

And that client's got to be prepared to

tell his or her story in an effective

way. And you got to get out of the way.

It's got to be the plaintiff's story.

But it takes a ton of hard

work to get the client there.

I agree with you so much.

Cool. Well, as expected, the three

minutes flew by, but any parting words,

Peter,

for younger folks starting out their

careers as trial lawyers or just trialers

these days? What advice do you

have to impart on our audience?

Oh boy, Kevin, I'm sure it's the same

thing that you do every day. Like I said,

I know you and just from the

International Academy, and boy,

what a mentor you are. But

first is take cases to trial.

There are just not enough

trials now. And obviously,

settle them in the appropriate case

and do what's best for your client.

But in terms of try your

cases and just do it.

Take care of yourself in the days leading

up to and during trial. Eat right,

get sleep. I had a trial lawyer, a good

trial lawyer out here in Colorado say,

sleep is a weapon. So make

sure you're getting some sleep.

Don't wait until shortly before

trial to start your prep.

There is so much stuff going on in trial

where you're going to be working really

hard outside the trial anyway.

Get your case as much as you can in the

can before you walk into the courtroom.

And then go with it and

listen and pivot and

adjust. But there's just too many things

happening during trial to be thinking,

well, I'm going to prepare my cross

the night before or whatnot. Mentor.

All of us should be mentoring younger

lawyers. Give them some witnesses.

Let them have some role. And the

judges love it. In my opinion,

Kevin, in my experience, they just do.

And it's kind of nice when you're in

a week-long trial or whatever it is,

and the judge says, "Mr. Koklanis, who's

your next witness?" And I say, "Ms.

Smith is going to be handling this."

And they kind of perk up, "Well,

let's see how this goes." And they love

it, and it's great for the profession.

And finally, and I've heard this so many

times, but I'll say it again, have fun.

Have fun. This is what we do. There's

nothing better. We're helping people.

We're in court. We're presenting,

we're advocating, we're competing,

and we're trying to get a good

result for our clients. So have fun.

Yeah. Well, Peter, that's incredible

advice. I can't agree with you more.

Trial is the most fun I

have professionally by far.

Getting ready for trial is no joke. It's

no joke. It's what I'm doing right now.

It is a grind. But man, once the lights

are on and you're in courtroom, and man,

this is what it's all about. So yeah,

thank you for imparting your wisdom.

Thank you for mentoring others.

It's so important. Look, my

days are numbered here, right?

I've got more yesterdays and

tomorrows as Bill Clinton would say,

but it's important that the

next generation get in there

because jury trials are

shrinking.

We need to get more people interested in

getting in court so the next generation

can exercise the Seventh Amendment and

we can have great trialers in the future.

And you're doing your part to do

that. So thank you, my friend.

Well, thank you, Kevin,

for all you're doing and for your

podcast and for including me because what

you're doing is, boy, it's so valuable.

And thank you for being out there and

doing what you're doing. Thank you.

All right. Thanks, Peter.

Thank you for listening

to Verdict Academy.

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