Jury Communications From Voir Dire to Verdict: Best Strategies for Selecting, Instructing, and Persuading Juries

Recording of a 90-minute CLE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Thursday, May 12, 2022

Recorded event now available

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Course Materials

This CLE webinar will guide personal injury counsel in best strategies for influencing and persuading the jury when communicating with the jury at critical points at trial--from voir dire to jury charges and instructions and verdict forms, all the way preserving error for appeal at each step along the way.


The first part of the program will guide counsel through best strategies to seat a jury and improve the probability of a verdict in favor of the client, persuade judges to expand oral voir dire, get jurors excused for cause, and test a potential member's views on the most unfavorable facts. The panel will also address legal and logistical issues unique to remote voir dire.

Even the perfect jury must grasp what they must decide--research demonstrates that most juries have great difficulty understanding and applying jury instructions. Counsel must draft clear jury charges and instructions to get to a verdict and defend it on appeal. Personal injury counsel must be cautious with special verdicts and know when and how to use them. To prepare for an appeal, counsel must preserve errors made in voir dire, jury charges, or verdicts.

Listen as this esteemed panel of experienced litigators guides counsel through communicating with the jury from voir dire through verdict.



  1. Voir dire, in person and remote
  2. Drafting clear jury charges in complex cases
  3. Crafting the verdict form and when to use special verdicts
  4. Preserving errors based on jury communications or misconduct


The panel will review these and other pivotal issues:

  • What are the key statutes that affect jury selection, charges, and errors?
  • Do peremptory challenges still exist?
  • How can counsel draft understandable jury instructions?
  • Can jurors be told why they are not to consider certain matters?
  • When can intermediate jury instructions be used?
  • What are the most common flaws in jury decision-making?


Pyers, Zachary
Zachary B. Pyers


Mr. Pyers litigates complex commercial, professional liability, tort, and class action matters. He represents clients...  |  Read More

Vartazarian, Steven
Steven R. Vartazarian, Esq.

The Vartazarian Law Firm

Mr. Vartazarian graduated cum laude from Oklahoma City University and cum laude from Thomas Jefferson School of Law. He...  |  Read More

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