31. When you first get a case, call opposing counsel and introduce yourself. It's harder for an attorney to be unprofessional if he's had a pleasant conversation with opposing counsel.
32. When the other side starts objecting during a deposition, you've tripped over something. When he starts making speaking objections, you've hit pay dirt. Keep digging.
33. When the other side vigorously objects to a request for production, there is a good chance you're about to unearth the proverbial smoking gun. It may take a motion or two to get it, but it will be worth the effort.
34. Instant oatmeal is great. Pour a pack into a styrofoam cup, fill with hot water, and voila, breakfast at the office.
35. If you are going to have breakfast at the office, make it a point to have breakfast with your kids on the weekend.
36. The first thing you do-read the jury instructions. They will be your road map for the entire case. They tell you what the parties have to prove, what the defenses are and whether you stand a chance of winning or not.
37. If you want your clients to be happy, act like the waiter at your favorite restaurant. At my favorite restaurant, the waiter sits us at our table, makes sure we have plenty of bread, brings out the kids meals first and keeps the soda glasses filled. He knows our needs, meets them and does it all with a smile. Provide that quality of service to your clients and they will keeping coming back.
38. Funny thing. The food at that restaurant is good, but not great. We come back for the service.
39. You can't win without a theme. Start developing the theme of your case early. Every interrogatory you propound, every motion you file and every deposition you take should be done to advance that theme. If you wait until two weeks before trial to develop your theme, it's too late.
40. However, don't be married to a theme. As your case develops, your theme must develop. During the course of litigation, you may pick up and drop a half a dozen themes on the way to finding one that is worth holding onto.