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Bulldog Maxims

  1. Be a “marine”- agile, hostile, mobile, adapt and overcome- find a way.
  2. You always have a move.
  3. You can control your outworking them.
  4. As in chess, think about what moves they will make to your moves.
  5. Never get spooked when you know you’re right. Double down.
  6. Make lists. Work the lists. Always reprioritize.
  7. The golden rule- “If they like what you’re doing, it’s bad for you. If they don’t like it, it’s good for you.”
  8. Delegate. Plan.
  9. Take action.
  10. Don’t piss down my back and tell me it’s raining.
  11. There are more failures from not going all in than anything else.
  12. It’s better to take some action with the most information you have than perfect information.
  13. Be nice.
  14. You will never have 100% information. Get the information you can and decide.
  15. A “nicked person” given a second chance can be a powerful and loyal asset.
  16. Retaining a valuable employee is less costly than training a new employee.
  17. A leader must work by example harder and longer than everyone else.
  18. A disloyal employee must be fired.
  19. “You get more with a kind word and a loaded gun than a kind word alone.”
  20. The key to all negotiations.
  21. Do not overplay your cards.
  22. Everything matters.
  23. Don’t let anything go unanswered.
  24. Every minute matters.
  25. When in doubt, leave it out.
  26. Don’t assume each juror is on the same page.
  27. The chain can’t be broken- liability, causation and damages.
  28. Their experts must be nicked.
  29. Remember that jurors are normal people.
  30. Empower the jury. They can do something good and important.
  31. Their heart will control their logic.
  32. It does no good to have facts and information unless it is summarized, organized and usable.
  33. Argue the case at all times.
  34. Admission or denial of the obvious.
  35. Stress 51%
  36. “Are you telling this jury”
  37. “Do you expect this jury to believe”
  38. You must address what the client gives input on.
  39. Do not lie to me.
  40. Humor me. The one with the responsibility.
  41. Preparation requires a script and organized testimony.
  42. Always review the exhibit index before finishing a witness.
  43. Always consult with the client before finishing a witness.
  44. Do not hide or ignore any bad fact. Refute it. Spin it. Debunk it. But address it.
  45. In closing, you must be able to refute anything they said by evidence or argument.
  46. Simplify everything.
  47. People remember what they see more than what they hear.
  48. Demonstrative exhibits.
  49. Summary exhibits.
  50. Let the client be themselves. Their testimony need not be perfect.
  51. It can’t be a discretionary medical decision.
  52. Put things in context.
  53. Keep table clean and organized. Regroup every night.
  54. Who does the jury believe? Win the believe battle.
  55. Treat jurors like your friends.