Tips on arbitration opening statements———>

Your opening statement is the one chance that you have to make a first impression.

It's the first chance you have to tell your story. And it's the only chance to warn me in advance about what I should be watching out for. I come to the hearing knowing nothing, and this is your chance to get in my head. This is your first final argument. This is your chance to tell your story before I hear the witnesses. So do one. Don’t skip it.

 Come into the hearing with an opening statement and start with a bang. Give me your theme. Tell me what your key witnesses are going to say. Tell me what your key documents are. If there's going to be a credibility problem in the case, explain to me in advance during the opening statement why your key witnesses are more credible or why their key witnesses are less credible, so when I hear those witnesses, I have your story about them in my mind, so I know what to watch for.

 When you do your opening statement do not shy away from your weak points and do not shy away from their strong points, because you know as well as I do that they will bring them up, and it's better if you bring them up first.

 So, do make an opening statement. Start with a bang. And then the hearing will go much better for you.

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