The last R for trial lawyers is remember. Once you relax , rehearse , and  react , you have to remember. Remember what happened , what worked , and what failed . Why do we want to remember ?  Great trial lawyers don’t want  to make the same mistake twice.

How do we remember ? We start with the creation of a trial journal . What would it contain ? Several years ago , I got a trial notebook written by Florida lawyer Elliott Wilcox . The basic idea of the notebook is to find the lessons learned and things to do differently. Here are some of the areas;

  • Theme
  • Jury selection
  • Opening statement
  • Direct examination.
  • Cross examination
  • Closing Argument
  • The most important lesson learned.

I write in the notebook after each trial. New lawyers should start one just for hearings or motion hearings. I hope you found the four Rs’ series helpful. I always invite your comments.