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How to Improve Your Opening Statements: GBW Geoff Wells Offers Storytelling Tips


GBW’s Geoff Wells recently shared advice about how to present effective opening statements at the fourth annual Southern California Trial Lawyers conference hosted by Pepperdine Law School. “The party that has the best story to tell wins the case,” said Wells who offered insight about the power of storytelling.

Wells shared examples from a recent trial that involved a child who suffered severe injuries after a car struck her while she tried to cross the street in order to board her school bus. The girl’s family sued Durham School Services for failing to report and prevent mid-street crossings, which is a blatant violation of their own policies and procedures.

Wells explained to the jury how It was a common practice for parents and students to cross the street mid-block directly in front of the Durham bus. All the parents with children at the same bus stop testified at trial that they never used the controlled intersection near the stop because they didn’t appreciate the danger and always crossed in the middle of the block. Parents testified they frequently crossed the street in plain view of Durham bus drivers who never took steps to prevent this behavior.

He also developed a narrative around how the bus drivers were the “eyes and ears for the school district” and that the district relied on drivers to report dangerous conditions at bus stops including unsafe mid-block crossings. The storyline was supported by trial testimony by witnesses for both Durham and the district who testified that an effective progressive discipline process is in place which begins with a verbal warning to parents and a written report and can escalate to students losing bus privileges if the behavior is not corrected. However, for the process to work, the dangerous behavior has to first be reported by drivers. According to testimony, the bus drivers never notified the district of the mid-block crossings.

“You’ll want to find a theme in your opening statements that resonates with the jury,” said Wells. “Storytelling is an art but it’s also a skill that you can always improve,” added Wells.