Since 2023, I have tried six punitive damages cases to verdict, each resulting in a punitive damages award against the defendants. The overall verdicts: $3M, $11M, $31M, $108M, $114M, and $550M.
In this lecture, I will provide in-depth training on the techniques I use to secure punitive damages in appropriate cases, beginning with case selection, continuing through each phase of discovery and trial, and ending with the punitive phase of trial after the compensatory verdict. I will teach you how I frame my cases around punitive damages, whenever possible, focusing on the following areas:
- Case selection for punitive damages.
- Getting punitive admissions during deposition to beat the inevitable MSJ and to set up for trial.
- Picking a jury that is ready to punish.
- Framing punitive damages in opening to set the tone for trial.
- Forcing admissions of punitive conduct with defense witnesses.
- Locking down punitive damages in closing.
- Winning the punitive damages phase--evidence and arguments.