When these principles are not followed, the probability of a runaway jury increases. In addition, the following are suggested as a list of “Do’s” and “Don’t’s” in preparing an important case:

Do:

• Check the credentials and background of a jury consultant.
  
  
• Know the venue and the judge thoroughly before the completion of discovery.
  
  
• Conduct exploratory research before discovery is complete.
  
  
• Implement a modern electronic presentation system.
  
  
• Incorporate research results into the design of demonstrative exhibits and graphics.
  
  
• Train witnesses with a systematic framework that ensures all tactical objectives are met.
  
  
• Ensure that all of the relevant case facts and issues are incorporated into the research.
  
  
• Run Mock Trials until the case is jury-ready.
  
  
• Insist on the compilation of a database that can identify favorable and unfavorable jurors.
  
  
• Ask the court for a Juror Questionnaire.
  
  
• Determine how jury selection and voir dire will be conducted well before the trial date.

Don't:

• Put off research until a month or so before trial.
  
  
• Allow plaintiff and defendant presentations to become slanted in a manner that biases the research outcomes.
  
  
• Send witnesses into deposition until they have been thoroughly prepared with a systematic framework.
  
  
• Use different trial consultants for different portions of the intervention system (e.g., one develops exhibits and the other trains witnesses).
  
  
• Rely on hunches when empirical evidence provides a contrary conclusion.
  
  
• Assume that experts are exempt from credibility problems, or that Witness Effectiveness training is not necessary for them.
  
  
• Use graphics, demonstrative aids, charts, and other media without testing their persuasive power and “jury-friendliness” first.
  
  
• Assume that jurors comprehend jargon, acronyms, or technical terms.
  
  
• Allow various members of the trial team to countermand or revise a trial strategy that is formulated based on the research.
  
  
• Allow opposing counsel to get their Juror Questionnaire to the judge first.
  
  
• Relegate voir dire and jury selection strategies to last-minute preparation.