Dirk's Dozen Voir Dire Questions

Dirk Vandever’s view of voir dire is that it is not separate and distinct from the rest of the trial but is the first (and most important) start of one interconnected process which links with every action and decision the lawyer makes until sitting down after rebuttal. He will share some of the questions that he either created or “purloined” from others over the past year in the never ending process of finding “impact” questions. The reality is that the PROCESS of creating those questions are far more important than a list of questions itself. Of great importance also is the manner in which those questions are asked. Dan Ambrose will bring his knowledge to bear on how to ask the questions to get the greatest return.

Risky Business” (I am looking at you motorcyclists)

  • (1) Fault: By choosing to get on a motorcycle you are “assuming the risk”;
  • (2) Damages: Impact on damages because a motorcyclist knows that if anything goes wrong it is going to be serious.

“Money is the root of all evil and cheapens human values”

  • (3) Who would not sue for (malpractice, death, etc.)
  • (4) “Suspicious Minds”: Find those suspicious of even neutral facts
  • (5) “Accident” v. Ordinary Care

"Your "ask" is ridiculous"

  • (6) Identify those who are never going to give that number
  • (7) Identify those would would be "open" to the idea if the evidence supports it

Prehabbing Throughout

  • (8) “Respect”: Building on Keith Mitnik’s idea of “mutual respect”, long before sitting down, implant the concept with virtually every “bad” answer.

“Following The Law”: The fairest person is the one who tells their truth

  • (9) Economic Damages (“bookkeeping” numbers):
    • a. Distinguish from the larger/more important; and
    • b. Emphasize where caps apply
  • (10) “Non-Economic Damages”: Human or quality of life (starting with “money for pain” and graduating to what is really valuable).
  • (11) Non-Economic damages linked with rich famous people
  • (12) Custom and Habit: “I always do it that way”

Baker’s Dozen

  • (13) It’s always about systems failure

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