005318TRIAL conducting the the trial 1

							The Trial
Opening Statement.
Advance your theory of the case
- AP is avoiding child support
- AP is abusive, using this to punish client
- AP angry that client left and/or has a boyfriend, using this to punish client
- AP was absent & disinterested, not bad dad, but client has been primary caretaker since…,
   and is best parent.
- Outline what you will prove that supports this. Don’t be too specific (to alert AP), but
   acquaint the judge with the case.
Don’t forget property and debts

Introduce any stipulations that have been agreed to
 - Regarding value of property, including pensions or retirement benefits,
 - Income of both parties
 - Marital debts

Witnesses
  Direct exam
  1. Opposing party as adverse witness
  2. Experts
           If they support your case- to introduce report and emphasize client’s strengths
           Possibly as adverse (unless you can get same mileage out of cross-examination
            during opposing party’s case)

   3. Occurrence witnesses
           Police officers, DCFS caseworkers, doctors re: abuse and to introduce
           Children’s teachers
           Neighbors, friends, day care providers, pastors and/or relatives who can attest to
             your relationship with, and care of, children, father’s behavior.
   4. Client
   Cross exam
   Rebuttal

  Exhibits
- Introduce any exhibits not yet in evidence
- Clarify those that your or opposing party have introduced if not clear about whether they
  were admitted or denied.

Closing argument
1. Should be written before you start. Thank the court for it’s time.
2. Use quotes from testimony that support your case
3. Hammer away at theory and evidence that supports it
4. Refer to exhibits that support your case.
5. Ask for what you want with specificity. Don’t forget property and debts