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Rich Newsome | Newsome Melton

Trial Lawyer John Uustal, with the Kelly and Uustal firm in Fort Lauderdale, Florida, has won some of the biggest verdicts in Florida over the last 20 years. Uustal has also built one of South Florida’s largest and most successful trial firms with a team of incredibly talented young lawyers who try dozens of cases every year.

In this week’s Trial School video, John shares a list of 15 things trial lawyers must do before trial. This is a practical, no-nonsense list that everyone should use before trial.

Be sure to watch the video, but here is the essence of John’s 15 things trial lawyers must do before trial:


  1. Prepare the case to the jury instructions.
  2. Develop and evolve Rules of the Road early.
  3. Find awesome lay witnesses and Paint them Pink.
  4. Know your client like the best friend whose family would ask to speak at the funeral.
  5. Practice the skills and know the law for voir dire in the jurisdiction you are in.


  1. Have video depositions in the can, cut to the bone, and then some.
  2. Plan your order of evidence, and coordinate with experts.
  3. Serve subpoenas and plan on calling records custodians.
  4. Know every piece of paper in the file.


  1. Look at the jury, not your notes.
  2. Be comfortable with silence.
  3. Listen to the witness.
  4. Don’t be afraid to object.
  5. Don’t be afraid to educate the judge, if necessary in front of the jury.
  6. Try the case in the courtroom, not the case in the file.