How do you know if your witness is credible? Is your evidence compelling—or confusing? And will a jury really care about those bright orange socks?
In this episode of the Emerging Litigation Podcast, trial attorney and focus group consultant Elizabeth Larrick joins me to explain how remote focus groups are changing the way lawyers prepare for trial. Elizabeth shares what she’s learned from conducting over 1,000 Zoom focus groups—insights on testing case narratives, assessing witness credibility, refining trial strategy, and even improving jury selection.
You’ll hear how quick, targeted virtual sessions help identify blind spots, shape more persuasive stories, and prevent courtroom surprises—while also giving lawyers valuable practice engaging with real people before trial.
Plus: What happens when jurors prefer the disheveled guy over the polished one? Why you should probably rethink those flashy shoes? And why, sometimes, less (facial expression) is more.
Thanks to Elizabeth for sharing her expertise—and her sharp eye for socks.
If you have comments or wish to participate in one our projects please drop me a note at Editor@LitigationConferences.com.
Tom Hagy
Litigation Enthusiast and
Host of the Emerging Litigation Podcast
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Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Tom Hagy (00:03):
Welcome to the Emerging Litigation Podcast.
I'm Tom Hagy, longtimelitigation enthusiast, editor,
publisher and now podcaster.
I'm founder of HB Litigation,which is now part of Critical
Legal Content, a business Ifounded in 2012 to serve as a
content marketing department forlaw firms and litigation
(00:24):
service providers.
And now here's today's episode.
If you like what you hear,please give us a rating.
If you want to reach me, pleasecheck out my contact
information in the show notes.
So, let's say, your caseinvolves a man who has suffered
traumatic brain damage and hisfamily, who has filed suit
(00:45):
against a company they blame forhis injuries, has found some
home movies of their dad playingcheerfully with his
grandchildren.
This was before the accident.
He was demonstrating a full setof faculties that that aren't
there after the accident.
You wonder how might a juryrespond to the video?
When in the trial should it bepresented?
(01:05):
Might there be any surprisereactions, unintended
consequences, I guess, to aside-by-side comparison of the
before and after of the man?
What if the video was uncoveredclose to trial?
You haven't had it all thistime and then it turned up in
the attic.
How are you going to getanswers about its use quickly?
How are you going to getfeedback on it in time to make
(01:27):
adjustments to your presentation.
That's what we're going to talkabout on today's episode of the
Emerging Litigation Podcast.
We're going to dive into asolution for this problem and
that is remote trial focusgroups, and we're going to talk
to Elizabeth Larrick, a seasonedtrial attorney who discovered
she had a knack and a passionfor jury research, for case
(01:48):
strategy and for preparingwitnesses, and she talks about
this all through the use offocus groups conducted remotely.
Now she's done more than athousand of these, can you
imagine, so she's got a lot ofexperience behind what she has
to say.
So listen in.
She's going to share theseinsights into conducting these
sessions and in a way that willempower attorneys to refine
(02:13):
their trial strategies Also willempower them to gauge the
credibility of witnesses andtheir own credibility, for that
matter.
It also can help measure thevalue of evidence and helps tell
compelling stories that win incourt.
We all want to win in court.
We all want to win in life.
But let's focus here.
(02:33):
We're going to talk about howvirtual focus groups differ from
traditional mock jurysituations, the unique
advantages of virtual focusgroups, how they can help
lawyers sharpen thesepresentations, the presentations
of their arguments and theirevidence.
We're also going to get a senseof how it can help determine
the value of cases.
We're going to touch on some ofthe little things, too, that
(02:54):
matter, like an attorney'schoice of socks how that might
sit with a jury if he comes inwhen they're particularly flashy
.
So who knew that they could bea factor in attorney credibility
?
But we all know such a thingcan.
It raises questions too, likewhich is worse?
Do you want to have an attorneywearing attention-grabbing
socks or no socks at all?
(03:15):
And Elizabeth and I kind oflanded on not wearing them could
be worse.
I guess it depends on ankles.
It all depends on the ankles,so let's not judge everybody.
We welcome your thoughts onthis, because we know you have
them and we want to hear them.
Sometimes I get off track, likeI think I just did.
We did end up talking about someof my favorite things, which is
a bizarre trend where peopleare using artificial
(03:37):
intelligence to turn themselvesback into babies.
You know videos, rather youknow than actually going back in
time.
So you know you've probablydone this, people have probably
done this for you.
Sometimes, though, when peopledo it, the baby image comes out
and the baby has a complete setof adult teeth.
It's a disturbing look.
It's more disturbing than youmight imagine and I'm going to
(03:59):
show you With that.
Check your socks, check yourbaby teeth.
Here's my interview withElizabeth Larrick of the Austin,
texas-based Larrick Law Firm.
I hope you enjoy it.
Elizabeth, thank you very muchfor talking with me today.
I really appreciate it.
This is an interesting topic tome and that's where you say
(04:19):
it's a pleasure to be here.
I've never been on such aprofessional.
No, I'm kidding.
Elizabeth Larrick (04:25):
I'm listening in for the cue and the space.
Tom Hagy (04:31):
Elizabeth, thank you very much for doing this today.
Elizabeth Larrick (04:34):
I'm so sorry I did it again.
Tom Hagy (04:36):
No, I don't care, let's forget it.
So, let's just get right to it.
So so why don't you tell me alittle bit about what you do
first, or tell me, or tell ourlisteners, what you do?
Elizabeth Larrick (04:48):
Yes, Tom.
Thank you so much for having meon the podcast.
I am excited to be here so muchthat I keep interrupting you.
Tom Hagy (04:54):
It's so natural it is so natural.
Elizabeth Larrick (04:56):
Yes, I am a lawyer here in Austin, Texas,
and I did plaintiff's personalinjury for many years.
Got in the courtroom, did sometrials and really just found
that I had a knack and a lovefor helping folks with focus
groups and witness prep.
And so I about five years ago,right before the pandemic,
turned everything over to dotrial consulting and wound on my
(05:20):
firm and so that's what I'vebeen doing here for the past
couple of years.
But all along I've always beendoing focus groups, been taught
witness prep, but really justhad a good sense of listening to
folks and being able to helplawyers understand that and then
translate that into openingstatements and jury selection
(05:42):
and fun stuff like a cross-exam.
Tom Hagy (05:44):
Okay, well, very cool.
So let me get started on thebasics.
Here we're talking about focusgroups.
We're talking about doing themvirtually, like we are right now
.
This is virtual, really.
No, it's not really virtual,it's just remote.
Virtual would be like if wewere avatars or something I
think, never mind.
Elizabeth Larrick (06:03):
I think people get a little.
It's one or the other.
Zoom focus groups generallygets us real specific about what
we're talking.
Tom Hagy (06:09):
Yeah, I'm an editor, so these things concern me a lot
.
It's like when we say oh is it,they say, is it a webinar or is
it a live meeting?
Well, it's both, you know whatI mean.
So all right, that's boring,let's dive in then to so talk
about kind of the basics of ofwhat we are and what we aren't
talking about with a Zoom focusgroup.
Elizabeth Larrick (06:33):
Yeah.
So you know we most time whenlawyers think about focus groups
, they think mock juries.
That is not what we're doingthrough Zoom.
It's just it's way toocomplicated.
So these are really simplegroups that meet for an hour,
two hours, three hours with, youknow, eight to 10, 12 folks.
And we're doing, you know,neutral feedback, you know, just
to find what our blind spotsare.
(06:54):
We're doing opening statementsto do some advocacy, to figure
out what are our case themes,and we can even do witness
credibility, have people watchclips and tell us what they
think.
So it's a very flexible spaceand what is so unique about
right now is so many people havethe technology and have used
Zoom, they have the internet,whereas before the pandemic it
(07:17):
really was impossible to find agroup of people who had all
those capabilities, and noweverybody does.
Tom Hagy (07:24):
Right, yeah, yeah, it was fun to hear some of the
stuff during during the pandemicof things that didn't go well,
but I remember there was, therewere actual trials taking place
and I do remember, you know,there were a couple of jurors
were.
One guy was pushing his grocerycart around with his kids, uh,
(07:44):
in the grocery store while hewas on trial.
Another one was just lying downin his bed and, uh, they were
thought.
They thought maybe he was goingto smoke pot or something, the
way he was kind of reaching for,uh, for something that looked
like a bong, but it turned outto be a soda bottle, but all
right.
So then there's the famous thecat lawyer.
Elizabeth Larrick (08:05):
Yes, yes.
Tom Hagy (08:06):
Yeah, God bless him.
I wish you'd look him up andsee what he's up to these days.
One thing you said about thesefocus groups is you can it's not
a whole like a mock jury, butyou can pinpoint specific issues
that you want to get feedbackon.
Is that right?
Absolutely yes, and that'sprobably the better way of
(08:29):
concisely saying it than the wayI did.
Elizabeth Larrick (08:31):
Yeah, that's why I did it.
Tom Hagy (08:32):
No, I didn't do it that way.
Well, okay, so one of thethings you also talked about was
was was witness credibility,which is really interesting, I
think, to me and would be toother attorneys.
So do you have some examples ofways you've tested witness
credibility in different typesof cases?
Elizabeth Larrick (08:55):
Yeah, and I would just say, from an
attention-grabbing standpoint,like people are into watching
videos, Like YouTube is stillthe number one search engine.
People are into watching videos.
Like YouTube is still thenumber one search engine, People
love it.
And so for us as lawyers tojust play small five
seven-minute clips of people andthen just ask people to judge
it like they love it, Likeabsolutely, so they get their
(09:16):
popcorn out Like they're into it.
So we have personal injurycases where we've done folks
just to try to figure out what'stheir credibility when they're
explaining their injuries.
We've had people who are indiscrimination cases where
they're having to describe whatit is and then basically asking
(09:39):
our focus group does that soundlike discrimination to you?
Because these people werehighly educated group of folks
and they were overcomplicatingit and so it became a like let's
test them before they go todeposition, because
discrimination case, if youdon't get it right, you're MSJ
it out and you know you've lost.
So that's a great place topractice when you have that kind
(10:03):
of pressure of an MSJ.
Um, that's a great place to topractice when you have that kind
of pressure of an MSJ.
But you know, one of thefunnest things about doing the
witness.
Credibility is the contrast,because what jurors are
comparing it to.
So you always like to have twopeople that are in the case so
they can contrast them and saylike, oh, that we liked that one
, or oh, we didn't like that one.
Or compared to them.
And so we we like to do this alot when we have our business
(10:26):
divorce cases, because youreally want to know, like, okay,
who's one credible, but alsolike, when you compare them side
by side, you know what whatends up happening in their minds
.
And Just here, a recent examplewe had was a super polished
witness.
He had on his blazer, he's gotthese great answers, he's very
(10:47):
polite.
And then the next guy was likethe disheveled guy.
Barely has his buttons on, helooks sweaty, and they felt so
bad for that guy and it was like, yeah, that was not what the
lawyers wanted to hear.
They wanted the you know, thepolished guy to be the, the, the
one, and he was too polished.
So then they were trying toscramble to get ready for trial
(11:09):
and it was just kind of like, ohmy gosh, if this character
shows up, this disheveled, youknow, I got to take an advantage
of person, Like they're notreal, like the jury's going to
go with that guy.
So it becomes reallyentertaining.
But also just when you havethis contrast of the different
witnesses, it really helpsamplify what your problems are
(11:30):
with your witness.
Tom Hagy (11:31):
Yeah yeah, the impressions that humans give on
other humans is like they sayit's within the first few
seconds.
So you, I, I, somebody oftensay oh, I feel bad for that guy,
Look at it?
Elizabeth Larrick (11:41):
Oh yeah, absolutely, and that's what we,
you know we ask them.
You know what question wouldyou, would you want to ask this
witness?
And I've had them come back andsay like I wouldn't ask that
guy anything.
He's never going to tell thetruth.
Tom Hagy (11:51):
Right, right, there you go.
Yeah, I saw, yeah, the twopolished thing could come up.
We had invited jurors to aconference of trial lawyers once
and they were from an actualcase and one of the lawyers was
there on the panel and one ofthe jurors I mean they, they're
not trying to impress anybody,they don't care.
They got there, we paid themsomething, they're, they're on
(12:11):
their way, they're going to losetheir jobs, and so the respect
they have for lawyers was it wasthey either did or didn't, but
anyway they, this guy came in,he's obviously fit, he's got his
thousand dollar suit on andhe's you know, uh, this watch
obviously was a rolex and allthis stuff, and the lawyer is
sitting there.
So I didn't want to hear fromhim, I didn't trust him, and the
lawyer is just sitting thererubbing his head.
(12:33):
It's like you know, here I amtrying to look professional and
and it's really it's workingagainst me yeah, and it's.
Elizabeth Larrick (12:41):
it is so amazing, having done as many
trials as I have, like thatlawyers will still kind of go
out of their way sometimes to beflashy, and I'm like you are
thinking yourself here like youdon't need the fancy socks like
or you know, or you're, you gota subtle tie that's got stuff on
it.
It's like you know, just Ithink it's funny.
You went tie, that's got stuffon it.
Tom Hagy (13:04):
It's like you know just, I think it's funny, you
went right to the socks.
Elizabeth Larrick (13:06):
I did I did.
Has that?
Has that come up before?
Yes, it has, they're like oh,really okay yeah, I was a lawyer
and he was, uh, he had on areally expensive pair of nikes,
which was unusual and then thesebright orange socks and I was
just like what, what?
What are we doing here, man?
Tom Hagy (13:22):
You know, yeah, all right.
Well, there's a key takeawayright there.
Elizabeth Larrick (13:26):
That's right.
That's right.
Please watch your socks.
Tom Hagy (13:29):
And you should wear them also, I think.
Elizabeth Larrick (13:31):
Oh yeah, well , yes, that's also very
important.
Tom Hagy (13:35):
So you've tested other credibility in other contexts.
You had mentioned Lisa.
You talked about discrimination.
What else did you have?
Did you have a PI case?
Elizabeth Larrick (13:44):
Yeah, a personal injury case.
You know, occasionally peoplewill get tripped up on our Fifth
Amendment right when it's likethere could be a place where
somebody should take it, butwhat does the jury think about
it?
And so you know we had hererecently where we tested both
ways right, where in one focusgroup he took the fifth.
In another focus group he justtold what happened and the gap
(14:08):
of imagination that allowedthose people to create the worst
case scenario was really like,oh my gosh, we really have to
now dig deep and figure out ifhe needs to take the fifth,
because it could really end uphurting his credibility.
Tom Hagy (14:23):
Right, sure, yeah, I can see where that.
Yeah, people make thatassumption.
Why would?
Why would you take it if youdon't have to?
Elizabeth Larrick (14:30):
And sometimes people don't penalize them,
like they're like, absolutely,if that's my right, like I'm not
gonna.
You know I'm not going to gettripped up by that, but I think,
because of the scenario of thiscase, where there was just this
giant gap of information,nobody was telling what happened
in this particular evening andso then it became okay, well,
(14:51):
you have the information andyou're not telling us.
You know versus just like youknow, were you drinking that
night?
I take the fifth.
You know?
Something simple like that.
Tom Hagy (14:58):
Yeah, that makes sense .
So, um yeah, so yeah, I'mjumping around a little, so
you'll just, you'll just.
Elizabeth Larrick (15:05):
I'll flow you go, just flow.
Tom Hagy (15:09):
So what about?
Because a lot of lawyers wantto know certainly what the value
of their case is, and assessingdamages, I don't know, maybe it
would help with settlement orsomething.
So what?
How does this?
Have you had experience withthat?
How does it work?
Elizabeth Larrick (15:23):
Yeah, that is like one of the number one
questions I get all the time islike well, they tell me how much
it's worth and I say, yes, butit's not really reliable.
It's just eight to 10 people.
I mean, there are other toolsout there that can really get
you much closer.
When you do like a big datastudy that's got 2,000, 3,000,
(15:43):
4,000 inputs, then you reallycan statistically come back down
to what would be.
But with these eight to 10people, what's more important is
just testing.
What is the information thatyou have?
A lot of times people rely onlife care plans.
Right, that put together howmuch people are going to need
(16:03):
for care and householdmodifications and medications
for the rest of their lives.
And it's fascinating to havejust testing that kind of
information, because we are, ashumans, programmed to focus on
the present right now.
Well, I will worry about thefuture later.
Like what's how?
You know that'll take care ofitself, and so it's very like
(16:26):
it's interesting and lawyerstake a lot for granted to think,
oh well, I put this together,we got a great doctor's going to
get up there, and I'm alwayslike, yeah, you need to test it
though, because you couldtotally lose a bunch of
credibility If you know they'resaying this guy needs a ramp and
he needs all these things andthen the guy lives in a house
with like a flight of stairs.
Yeah Right, yeah, they're goingto put that together real
(16:49):
quickly.
So you know, some of thoselittle things of testing like
the credibility of it and andputting together the story of
the damages itself is sometimespretty precarious if you don't
have enough before and afterwitnesses or just relying on,
like maybe a spouse or a child.
You know there's a little bitof credibility there.
(17:11):
So it's helpful just to havethose pieces tested to make sure
we're good or we're missing onstuff.
And going back to those videos,you know one of the coolest
focus groups I've done hererecently was an older gentleman
had a traumatic brain injury andno doubt I mean got hit right
(17:33):
on the noggin.
You know we can't dispute that.
But what was cool was hisdaughters had taken videos of
him with his grandkids beforeand then after, and it was night
and day.
And the focus group was like wewere so glad we had those 30
second clips of him, you know,playing whack-a-mole with the,
with the little kid, or holdingthe baby, and then afterwards
(17:55):
like there's just you know yeahcan't do any of that.
So it's it, do any of that.
So it's amazing, like thelittle things that we may have
in our lives that really helpjurors understand damages.
Tom Hagy (18:06):
Yeah, so you're using images, tell a story and you're
presenting evidence.
So for lawyers who want to usethis, can you help them craft
the sequence of events intelling these stories?
Elizabeth Larrick (18:22):
Yes, yeah, I mean I think with focus groups
they really tell you thesequence you need, because we'll
, we'll, you know, fashion thestory one way and then come back
and do it in a different way tosee which way hits them.
But yeah, from a from astandpoint of brain science and
like primacy, what are we sayingfirst, recency, what are we
(18:43):
saying you know last, but howare we helping create the story
that we have to be veryconscious of organizing it,
otherwise it's just mass chaosin their minds, it's just
confusion.
Tom Hagy (18:52):
Right.
Yeah, it's just kind of a firehose, that's right.
Look at all the stuff I'vegathered.
Now I will blast it at you.
So have you had examples where,leading up to trial, that the
focus group has shifted causedthe lawyer to want to shift
their strategy?
Elizabeth Larrick (19:11):
Absolutely, absolutely.
We recently tested a case.
They were right on the doorstepof within 30 days.
They were coming up and theyhad, I would say, probably three
, what they considered keyviolations by the defendant.
And there were more, but theythought these three, these were
(19:31):
the most important violations.
And we put it to a focus groupand tested it and it came back.
They had one right, but theyhad two others that were a lot
stronger.
So what we did was we took thatinformation, we rearranged
their opening to focus on thosetop three and then took the rest
though we didn't ditch it, weput it into cross-exam and then
(19:54):
in closing, he was able to saywe prove these three things, but
then we also prove these otherthree.
So they had you know more ontheir list of things they proved
, but then we also prove theseother three.
So they had you know more ontheir list of things they prove.
But it became super importantto just focus on those three for
opening instead of trying togive them all six.
Tom Hagy (20:11):
Yeah.
Elizabeth Larrick (20:12):
And prioritize it in order of like
first in time.
Tom Hagy (20:16):
Yep, I gotcha, yeah yeah.
The sequence I'm telling astory is obviously critical to
how effective it is, how peoplereceive it and remember it, and
so you've mentioned a couple oftimes you know people love
videos.
How are you able to effectivelypresent demonstrative evidence,
(20:37):
pictures, other things thatpeople can look at and engage
their reaction to those things?
Elizabeth Larrick (20:44):
Absolutely.
I have a good relationship witha medical illustrationist and
she works with another lawyerthat we do a lot of focus groups
and we will just put thoseimages up.
What makes sense?
Does it look bad?
Could you gather all?
You gather all these injuries?
Or maybe it's too much.
So those are also really easy,quick ways where it's just you
(21:06):
know show them the picture andkind of ask them what's injured.
You know, because sometimespeople will say you'll have a
group of people that get it andthen you'll have a group of
people who are like I need youto walk me through this.
So there's always a littlebalance.
I think for everybody who'ssitting on the jury you need to
have a nice balance.
But sometimes you get thesemedical illustrations and
there's 50 words on the side ofthe image and they're like I
(21:30):
can't even pronounce that.
Tom Hagy (21:31):
I'm like.
I can't either, so take it offSome of the animations I mean, I
haven't seen any even recently,but they used to be some of
them were just so incredible.
You know 3d animation, Iimagine now, with animation and
AI and things, they must be ableto create some incredible.
You could turn people intobabies, for example, babies that
(21:56):
have an unusual amount of teeth.
That's right.
Elizabeth Larrick (21:59):
Yes, I, I definitely.
Tom Hagy (22:00):
I have seen that recently you've seen that what
kind of a bizarre person wouldmake a baby of themselves with
teeth?
That's just so strange.
Have you seen?
This is a complete sidetrack.
Of course we're talking aboutyou, but um, we have you.
Have you seen?
There's a clip where, uh, ahusband it looks like he's
coming home from work he'sdragging there's a baby in the
(22:21):
high chair and mom had paintedeyebrows on the baby.
It's, yeah, it's the best, okay, um making fun of babies.
Elizabeth Larrick (22:30):
I mean it's hilarious.
Tom Hagy (22:33):
Yeah, yeah.
I don't know why babies are sofunny.
You know, just a very basiclevel where?
Where are these people when,when you're doing this?
So they just sitting at home,or they you know the grocery
store?
What?
Where are these people whenyou're doing this?
Are they just sitting at home?
Are they, you know, at thegrocery store?
How are you setting it up?
Elizabeth Larrick (22:46):
We don't let them do grocery store.
We, you know, we obviously haveto set some rules up.
They can't be driving in a car,they can't even be a passenger
in a car and, trust me, I've hadpeople show up on the bus and
I'm like this not gonna workright, so uh, so yeah, we have a
little bit of rules, but mostof the time they're showing up
at their kitchen table, or wedefinitely have people who show
up sitting in their bed and yeah, yeah you know, we, just you
(23:10):
know, we have a few lightingrequirements and things like
that, and you know, please trynot to smoke.
But you know again, the morerelaxed people are, the better
feedback you get try, try not tosmoke.
Tom Hagy (23:22):
I think that's a good tip.
I think for anybody on Zoomit's like you must when they do
that you just take it to blackand white and it'll look like a
talk show from the early 60sbecause everybody was smoking.
So are there any likemisconceptions that people would
have about this?
When you approach lawyers, Tellme what that conversation is
(23:43):
like.
Elizabeth Larrick (23:44):
I think one.
Most people are like whoa,you're using Zoom to do this?
I never would have thoughtabout that.
Like absolutely using Zoom.
People have a misconception thatthese are giant six-hour Zoom
mock juries and they're just not.
I mean, these are like you said.
They're issue spotting, they'refinding our weaknesses, they're
(24:06):
quick check-ins to see and getan outside perspective and, um,
you know, they're not intendedto replace a mock jury, but
they're intended to you be ableto get an?
Um, a look at what the jurorsthink before you begin discovery
, after you take that majordeposition.
Did you score all the berriesin the bucket or was it just you
(24:27):
, you know, bravado, thinkingyou got the, you got the person.
So, and I would just think mostpeople when I tell them you can
do this, you, somebody in youroffice, can learn to do this
that there generally is like ohwell, you know what if we do it
wrong, right.
Most of the time I'm like, ohwell, you know what if we do it
wrong, right.
Most of the time I'm likeyou're still going to learn
something, even if you do itwrong?
Tom Hagy (24:45):
Yeah, you've learned that you need to learn how to
use Zoom.
Elizabeth Larrick (24:48):
That's right, or you know, have somebody else
do it, because you argue witheverybody yeah.
It's always a goodcommunication skills at all
levels when you're doing theseas a lawyer.
Tom Hagy (25:02):
So are lawyers also presenting on these?
Of course they are, yeah, so oh, that must be great education
for them.
Elizabeth Larrick (25:10):
I I always hope that people see that
there's a lot of value in justgetting up and presenting to a
group of strangers who, like,they'll look at you, get a third
head, or they'll tell you likethat's dumb, Like yeah, yeah.
Tom Hagy (25:29):
So as as as a podcaster who I only thought I
was going to be doing audio, uh,when I started doing video, I
came to realize, my God, I makea lot of faces.
I, I, I'm paying attention toevery word, but sometimes I'm
like my eyes are doing things Idon't even know about.
I'm looking in different.
I mean it's like just payattention, man, you know, just
focus.
Elizabeth Larrick (25:46):
It's it.
You don't you underestimate howmuch you move and your
mannerisms, and very few peoplenaturally have that.
Not going to move, affect thetotal skill.
When, when people say affectlike a total skill, when people
say, oh, that's just natural,I'm like no, it's not.
(26:07):
Trust me, I have seen the bestof the best and it is a hundred
percent a skill you have topractice.
Tom Hagy (26:12):
Yeah, I first found out about it from my wife
because we would haveconversations and she would say
things and I think I'm justlistening and she's saying why
are you making that face?
I'm like I'm just listening toyou saying what, what's?
Why are you making that face?
I'm like I'm not, I'm not, I'mnot making you.
You clearly don't want to dothis or you don't like this
person.
I'm like, no, what are youtalking about then?
I didn't.
I see myself on here.
I'm doing this like oh yeah, Ithink I have a very expressive
(26:36):
face, so I have to like pokerface it like you.
Yeah, there's a fine linebetween looking psycho though.
You know what I mean.
You don't want to just like yeah, you got to get the nod, the
journalist nod, and then yes,they're very good at that on
like the daily shows and thingslike that, where they mimic
reporters.
They're like they're listeningwhile they wait.
Are the um?
(26:57):
Are the people you pull in?
Like I wonder, are you able totest, like different
jurisdictions, or that would beinteresting to me.
It's like, ok, well, we'regoing to, maybe we're going to
do this, try this in the city, Idon't know Houston or whatever,
but maybe Beaumont or maybePort Arthur.
Yeah, I'm showing off by allthe different towns.
Elizabeth Larrick (27:16):
You are, look at you.
Tom Hagy (27:17):
Yeah, yeah, but because the different jury polls
are going to be different.
Elizabeth Larrick (27:23):
You ever use it that way.
Yeah, absolutely, absolutelyCool.
Yeah, we tried to do as as muchas we can.
We try to make.
Uh, if people want veryspecific like we have to have
all people from Port Arthur uh,generally I say like okay, well,
let's, let's get a little bitwider, cause, guess what.
It's okay if somebody you knowis in Pasadena or you know like
30 miles down the road.
We're not going to be toodifferent.
(27:43):
But I'm not going to put you aDallas person in there, you know
.
But we have general groupswhere it's just generally Texas,
oklahoma, where that's going tobe fine for the majority of
issue spotting or weaknesses andstrengths.
Tom Hagy (27:56):
Yeah, yeah.
It would just be so fascinatingto test different parts of the
country too.
I mean, I don't know, youprobably haven't had to do that,
but I don't know.
It's just interesting for me,like, how does a New Yorker see
something versus somebody fromOklahoma City or something?
Elizabeth Larrick (28:12):
Well, we did some testing for some folks that
were going to trial and theywere very similar cases, but one
was in Seattle and one was inSouth Dakota.
So we ran the exact samepresentation but in two
different places and it wasfascinating how they had
similarities but then they hadcomplete differences on how they
(28:33):
thought about these bigtrucking companies.
Tom Hagy (28:35):
Yeah, I'll bet they did.
Yeah, that's interesting.
Yeah, going to different partsof the country, I was going to
say something political, but uh,I won't.
No, just no.
Just because, um, just just sayI think, uh, politically, I
felt like I was in one spot onthe spectrum until I went to
portland oregon and I found out,oh, I'm really not that far off
(28:57):
, I'm not that far from centeras I thought.
Elizabeth Larrick (29:01):
All about context, all about context.
Tom Hagy (29:03):
Wow, I was blown away.
I was like because I leanliberal, I should say that.
And then I went out there and Ithought, oh wow, I can see why
people find us annoying.
Sorry, I'll probably cut thatwhen conversations start off
with I don't know how you feelabout the police.
(29:24):
I'm like well, I feel largelypretty good about the police.
Elizabeth Larrick (29:37):
Okay, I'm going to cut that fascinating
and listening to people.
And because news used to stick.
News stories would stick andpeople would talk about it.
But the news, information,travels so fast that things just
don't even stick anymore.
And so my example that is herein Austin we had an Amazon truck
(30:00):
that, for whatever reason, wentoff the rails, not paying
attention, end up running into,think, 10 or different cars,
killed five people instantly,and it was on the news for, you
know, days and days and days anddays.
Well, shortly thereafter, I hada focus group and I know it made
national news.
(30:20):
But we had a focus group just inSan Antonio, not a peep, and we
had we were doing a case withAmazon involved and I was just
like, how is it that this is notnobody brought this up?
But it happens more often thatyou think that we lawyers think,
oh well, that's going to be topof mind, that's going to be
something people are going to bethinking about, and I have to
tell them, like it's not,because you pick up your phone,
(30:43):
you're in a whole differentworld.
You put your phone back down.
Like you know, we have so muchinformation that rushes at us
that, as lawyers, we reallycan't rely on.
Oh, people are going to bethinking about that.
We really have to be veryconscious and focused about what
we give people to think, abouthow we organize it, because
(31:05):
while we think people may havegrasped that story or grasp the
importance of having rules forlike, they don't, it just goes
in one ear and out the other soit's definitely one of those
observations that I've seen, andalso people you know always ask
me, well, what about politicalaffiliation?
And in the past few years I cantell you like always ask me,
(31:25):
well, what about politicalaffiliation?
And in the past few years I cantell you like that is just not
a moniker of trying to figureout who the juror is for you or
is not for you, Because you askpeople they don't know either.
They're guessing right.
You may ask somebody who theyvoted for, but that doesn't
necessarily at all translateinto what we used to or what the
science, the jury science, usedto be was oh well, if you're
(31:47):
red, then we're, then you'regoing for this, or if you're
blue, I mean, it's just like.
No, it's, it's out the windowright now and it's not anything
that when I people ask me, I'mlike please don't rely on that.
Like yeah people just don't knowand they're just as confused as
we are about it.
So it's not a way to, like youknow, put somebody in a camp of
a yes or no for your case.
Tom Hagy (32:07):
Texas.
Also, tara Trask.
I don't know if you know her,but she she was talking about
how people and she's doing juryselection, how differently
(32:29):
people are consuming their newsand how the news is influencing
their opinions of of experts.
Elizabeth Larrick (32:37):
Well, so, fascinatingly, people I think
it's like it's an unnormalamount of people are getting
their news from social media.
And lawyers think, well, that'sthe question I need.
But you have to go deeper thanthat.
Because it's like what socialmedia?
Because you know, if 50% ofadults are consuming their news
(32:57):
on social media, but which is it?
Because TikTok, unfortunately,is a lot of people's news source
.
But then the crazier thing islike people that are following
or getting their news fromsocial media are following like
news promoters, not actual newschannels or actual journalists.
So it's very skewed and it'skind of all over the board.
(33:21):
So when people ask it used tobe a very popular question well,
how do you get your news?
But now it's like, okay, well,what's what social media channel
is it?
And you know how?
How do we draw conclusions fromthat?
Well, I mean, it's just thatthe news is very skewed, yeah,
yeah.
What you're watching.
Tom Hagy (33:46):
Yeah, it is, and I'm, I mean I'm, I'm a trained
journalist and you know, andI've, uh, and I mean I and I
watch the news.
I, I love social media.
I get a kick out of it.
I follow comedians and, um, Ilove, I'm a drummer.
I love drummers.
I see how, I see what aterrible drummer I am.
But I also look, look for newsand sometimes I'm just I'm, I'm,
I'm appalled at how twistedsome stories are.
(34:07):
Or they'll put up a screamingcaption.
It's so funny.
And recently I um, you seetestimony and you know,
different outlets will say lookhow this guy, you know,
destroyed this witness, and thenlook how this witness destroyed
the Senator and his same clipand, um, and some of them are
like it's clips from you don'teven know when they're from like
(34:30):
when did this happen?
What, what, what did it happen?
Then you look even closer andit's like, oh, this is AI, this
isn't even.
I mean, you know so and I'msupposedly trained in this.
Uh, I don't know, I don't know.
I worry about what people arebeing trained or being how
they're being educated.
Elizabeth Larrick (34:48):
Yeah, yes, and that's why I said like now,
I mean not, you know, definitelymore than ever, but yeah, now
it is so vital and important for, as lawyers standing up in the
courtroom with jurors, to benumber one teachers, because we
have to, well, one, do the juryresearch to figure out what the
(35:09):
attitudes are, what are you upagainst?
And then number two, to come inand understand like it's.
You know it's.
It's a mile wide but an inchdeep.
People don't know unlessthey're have had their specific
life experience, which is thesame as the case, which is
really rare, you know, reallystanding up and putting your
teacher hat on in a way to helpthem come to the education they
(35:29):
need to to then make decisionsin the case.
Tom Hagy (35:32):
Yeah, yeah, that's good advice, just educating them
Also without making them feelstupid.
Elizabeth Larrick (35:40):
What a challenge for most lawyers.
I kid, I kid, I love all thelawyers I know you do, so do I?
Tom Hagy (35:48):
I have loved them for over 40 years.
I'm often the guy defendinglawyers.
You know I'm a lawyer.
I'm like, oh God, please don'tdo that.
A lawyer is the person you'regoing to want when things really
hit the fan for you, personyou're going to want when you
are, when things really hit thefan for you and 99.9% of them
are just awesome, just trying tomake a living, trying to do the
(36:09):
right thing and, yes, of course, so you use it to also help
people pick jurors, I guess, orget an idea of, maybe, what kind
of jurors they want.
Is that something you do?
Elizabeth Larrick (36:17):
Yeah, Sometimes I think if you're
going to do that you have to doseveral, like you have to do
quite a few to be able to kindof put all that information
together.
But a lot of times what we'redoing is we're getting people
just to practice, and hearingreactions to your questions and
being able to navigate.
I mean that is a huge skill inand of itself for jury selection
(36:38):
.
Tom Hagy (36:39):
Yeah, very cool, all right.
Well, I really appreciate it.
Elizabeth Larrick (36:50):
Yeah very cool, all right.
Well, I really appreciate it.
Any final thought you want togive somebody, if you had like
30 seconds to say why you shouldtry this, why you should do a
focus group by Zoom, is mindblowing and inspire so many
ideas and creativity for trial,beyond what you and your team
can come up with because you'rein that box.
They're in a whole other boxand if you can spend an hour or
(37:11):
two hours with folks and learnthree or four things that will
take your case to the next level, just do it.
It's very inexpensive, it'seasy to do.
I've got lots of resources onmy website, two really large
blogs.
I've done podcast episodesabout it and even offer free
webinars that are once in awhile for lawyers to learn how
to do it.
Tom Hagy (37:31):
Okay, good, maybe we'll do another podcast and
then we can have focus groupfolks watch and judge me.
Elizabeth Larrick (37:39):
Okay, I mean, if you want that, I mean.
Tom Hagy (37:46):
okay, I just want, I mean, if you want that, I mean
most lawyers do not do not wantto do that, they are not into
that.
I would think it'd be anawesome service for an associate
you know to get on and do this.
I just think it would be agreat service for them.
So, elizabeth larick, thank youvery much for talking with me
today.
Elizabeth Larrick (37:57):
It was a pleasure oh, thank you so much
for having me.
I really enjoyed my time.
Tom Hagy (38:05):
Yeah, this is helpful.
So I'll go through this andsend it to you and if you tell
me, you know you were extremelyarticulate.
I didn't hear anything thatyou'd be embarrassed by.
Elizabeth Larrick (38:18):
It's okay if it's in there.
I do all my own stunts, so whenI see something that sucks, I'm
like I'm it's in there.
Tom Hagy (38:23):
I do all my own stunts , so when.
Elizabeth Larrick (38:23):
I see something that sucks, I'm like
I'm leaving that in there.
Tom Hagy (38:25):
The Emerging Litigation Podcast is a
production of Critical LegalContent which owns the awesome
brand HB Litigation.
Critical Legal Content is acompany I founded in 2012.
That was a long time ago.
What we do is simple we createcontent that's critical on legal
topics for law firms and legalservice providers.
I believe we even have a catchytagline, which is your legal
(38:48):
content marketing department.
That kind of content can beblogs, papers, they can be
podcasts, webinars and we have agood time doing it and S4HB
litigation.
Well, that's the name underwhich we publish interesting at
least interesting to me legalnews items, webinars, articles,
guest articles, all on emerginglitigation topics.
(39:08):
That's what we do.
Once again, I'm Tom Hagee withCritical Legal Content, nhb
Litigation.
If you like what you hear andyou want to participate, give me
a shout.
My contact information is inthe show notes.
Thanks for listening.
Welcome to the Emerging Litigation Podcast.
I'm Tom Hagy, longtimelitigation enthusiast, editor,
publisher and now podcaster.
I'm founder of HB Litigation,which is now part of Critical
Legal Content, a business Ifounded in 2012 to serve as a
content marketing department forlaw firms and litigation
(00:24):
service providers.
And now here's today's episode.
If you like what you hear,please give us a rating.
If you want to reach me, pleasecheck out my contact
information in the show notes.
So, let's say, your caseinvolves a man who has suffered
traumatic brain damage and hisfamily, who has filed suit
(00:45):
against a company they blame forhis injuries, has found some
home movies of their dad playingcheerfully with his
grandchildren.
This was before the accident.
He was demonstrating a full setof faculties that that aren't
there after the accident.
You wonder how might a juryrespond to the video?
When in the trial should it bepresented?
(01:05):
Might there be any surprisereactions, unintended
consequences, I guess, to aside-by-side comparison of the
before and after of the man?
What if the video was uncoveredclose to trial?
You haven't had it all thistime and then it turned up in
the attic.
How are you going to getanswers about its use quickly?
How are you going to getfeedback on it in time to make
(01:27):
adjustments to your presentation.
That's what we're going to talkabout on today's episode of the
Emerging Litigation Podcast.
We're going to dive into asolution for this problem and
that is remote trial focusgroups, and we're going to talk
to Elizabeth Larrick, a seasonedtrial attorney who discovered
she had a knack and a passionfor jury research, for case
(01:48):
strategy and for preparingwitnesses, and she talks about
this all through the use offocus groups conducted remotely.
Now she's done more than athousand of these, can you
imagine, so she's got a lot ofexperience behind what she has
to say.
So listen in.
She's going to share theseinsights into conducting these
sessions and in a way that willempower attorneys to refine
(02:13):
their trial strategies Also willempower them to gauge the
credibility of witnesses andtheir own credibility, for that
matter.
It also can help measure thevalue of evidence and helps tell
compelling stories that win incourt.
We all want to win in court.
We all want to win in life.
But let's focus here.
(02:33):
We're going to talk about howvirtual focus groups differ from
traditional mock jurysituations, the unique
advantages of virtual focusgroups, how they can help
lawyers sharpen thesepresentations, the presentations
of their arguments and theirevidence.
We're also going to get a senseof how it can help determine
the value of cases.
We're going to touch on some ofthe little things, too, that
(02:54):
matter, like an attorney'schoice of socks how that might
sit with a jury if he comes inwhen they're particularly flashy
.
So who knew that they could bea factor in attorney credibility
?
But we all know such a thingcan.
It raises questions too, likewhich is worse?
Do you want to have an attorneywearing attention-grabbing
socks or no socks at all?
(03:15):
And Elizabeth and I kind oflanded on not wearing them could
be worse.
I guess it depends on ankles.
It all depends on the ankles,so let's not judge everybody.
We welcome your thoughts onthis, because we know you have
them and we want to hear them.
Sometimes I get off track, likeI think I just did.
We did end up talking about someof my favorite things, which is
a bizarre trend where peopleare using artificial
(03:37):
intelligence to turn themselvesback into babies.
You know videos, rather youknow than actually going back in
time.
So you know you've probablydone this, people have probably
done this for you.
Sometimes, though, when peopledo it, the baby image comes out
and the baby has a complete setof adult teeth.
It's a disturbing look.
It's more disturbing than youmight imagine and I'm going to
(03:59):
show you With that.
Check your socks, check yourbaby teeth.
Here's my interview withElizabeth Larrick of the Austin,
texas-based Larrick Law Firm.
I hope you enjoy it.
Elizabeth, thank you very muchfor talking with me today.
I really appreciate it.
This is an interesting topic tome and that's where you say
(04:19):
it's a pleasure to be here.
I've never been on such aprofessional.
No, I'm kidding.
Elizabeth Larrick (04:25):
I'm listening in for the cue and the space.
Tom Hagy (04:31):
Elizabeth, thank you very much for doing this today.
Elizabeth Larrick (04:34):
I'm so sorry I did it again.
Tom Hagy (04:36):
No, I don't care, let's forget it.
So, let's just get right to it.
So so why don't you tell me alittle bit about what you do
first, or tell me, or tell ourlisteners, what you do?
Elizabeth Larrick (04:48):
Yes, Tom.
Thank you so much for having meon the podcast.
I am excited to be here so muchthat I keep interrupting you.
Tom Hagy (04:54):
It's so natural it is so natural.
Elizabeth Larrick (04:56):
Yes, I am a lawyer here in Austin, Texas,
and I did plaintiff's personalinjury for many years.
Got in the courtroom, did sometrials and really just found
that I had a knack and a lovefor helping folks with focus
groups and witness prep.
And so I about five years ago,right before the pandemic,
turned everything over to dotrial consulting and wound on my
(05:20):
firm and so that's what I'vebeen doing here for the past
couple of years.
But all along I've always beendoing focus groups, been taught
witness prep, but really justhad a good sense of listening to
folks and being able to helplawyers understand that and then
translate that into openingstatements and jury selection
(05:42):
and fun stuff like a cross-exam.
Tom Hagy (05:44):
Okay, well, very cool.
So let me get started on thebasics.
Here we're talking about focusgroups.
We're talking about doing themvirtually, like we are right now
.
This is virtual, really.
No, it's not really virtual,it's just remote.
Virtual would be like if wewere avatars or something I
think, never mind.
Elizabeth Larrick (06:03):
I think people get a little.
It's one or the other.
Zoom focus groups generallygets us real specific about what
we're talking.
Tom Hagy (06:09):
Yeah, I'm an editor, so these things concern me a lot
.
It's like when we say oh is it,they say, is it a webinar or is
it a live meeting?
Well, it's both, you know whatI mean.
So all right, that's boring,let's dive in then to so talk
about kind of the basics of ofwhat we are and what we aren't
talking about with a Zoom focusgroup.
Elizabeth Larrick (06:33):
Yeah.
So you know we most time whenlawyers think about focus groups
, they think mock juries.
That is not what we're doingthrough Zoom.
It's just it's way toocomplicated.
So these are really simplegroups that meet for an hour,
two hours, three hours with, youknow, eight to 10, 12 folks.
And we're doing, you know,neutral feedback, you know, just
to find what our blind spotsare.
(06:54):
We're doing opening statementsto do some advocacy, to figure
out what are our case themes,and we can even do witness
credibility, have people watchclips and tell us what they
think.
So it's a very flexible spaceand what is so unique about
right now is so many people havethe technology and have used
Zoom, they have the internet,whereas before the pandemic it
(07:17):
really was impossible to find agroup of people who had all
those capabilities, and noweverybody does.
Tom Hagy (07:24):
Right, yeah, yeah, it was fun to hear some of the
stuff during during the pandemicof things that didn't go well,
but I remember there was, therewere actual trials taking place
and I do remember, you know,there were a couple of jurors
were.
One guy was pushing his grocerycart around with his kids, uh,
(07:44):
in the grocery store while hewas on trial.
Another one was just lying downin his bed and, uh, they were
thought.
They thought maybe he was goingto smoke pot or something, the
way he was kind of reaching for,uh, for something that looked
like a bong, but it turned outto be a soda bottle, but all
right.
So then there's the famous thecat lawyer.
Elizabeth Larrick (08:05):
Yes, yes.
Tom Hagy (08:06):
Yeah, God bless him.
I wish you'd look him up andsee what he's up to these days.
One thing you said about thesefocus groups is you can it's not
a whole like a mock jury, butyou can pinpoint specific issues
that you want to get feedbackon.
Is that right?
Absolutely yes, and that'sprobably the better way of
(08:29):
concisely saying it than the wayI did.
Elizabeth Larrick (08:31):
Yeah, that's why I did it.
Tom Hagy (08:32):
No, I didn't do it that way.
Well, okay, so one of thethings you also talked about was
was was witness credibility,which is really interesting, I
think, to me and would be toother attorneys.
So do you have some examples ofways you've tested witness
credibility in different typesof cases?
Elizabeth Larrick (08:55):
Yeah, and I would just say, from an
attention-grabbing standpoint,like people are into watching
videos, Like YouTube is stillthe number one search engine.
People are into watching videos.
Like YouTube is still thenumber one search engine, People
love it.
And so for us as lawyers tojust play small five
seven-minute clips of people andthen just ask people to judge
it like they love it, Likeabsolutely, so they get their
(09:16):
popcorn out Like they're into it.
So we have personal injurycases where we've done folks
just to try to figure out what'stheir credibility when they're
explaining their injuries.
We've had people who are indiscrimination cases where
they're having to describe whatit is and then basically asking
(09:39):
our focus group does that soundlike discrimination to you?
Because these people werehighly educated group of folks
and they were overcomplicatingit and so it became a like let's
test them before they go todeposition, because
discrimination case, if youdon't get it right, you're MSJ
it out and you know you've lost.
So that's a great place topractice when you have that kind
(10:03):
of pressure of an MSJ.
Um, that's a great place to topractice when you have that kind
of pressure of an MSJ.
But you know, one of thefunnest things about doing the
witness.
Credibility is the contrast,because what jurors are
comparing it to.
So you always like to have twopeople that are in the case so
they can contrast them and saylike, oh, that we liked that one
, or oh, we didn't like that one.
Or compared to them.
And so we we like to do this alot when we have our business
(10:26):
divorce cases, because youreally want to know, like, okay,
who's one credible, but alsolike, when you compare them side
by side, you know what whatends up happening in their minds
.
And Just here, a recent examplewe had was a super polished
witness.
He had on his blazer, he's gotthese great answers, he's very
(10:47):
polite.
And then the next guy was likethe disheveled guy.
Barely has his buttons on, helooks sweaty, and they felt so
bad for that guy and it was like, yeah, that was not what the
lawyers wanted to hear.
They wanted the you know, thepolished guy to be the, the, the
one, and he was too polished.
So then they were trying toscramble to get ready for trial
(11:09):
and it was just kind of like, ohmy gosh, if this character
shows up, this disheveled, youknow, I got to take an advantage
of person, Like they're notreal, like the jury's going to
go with that guy.
So it becomes reallyentertaining.
But also just when you havethis contrast of the different
witnesses, it really helpsamplify what your problems are
(11:30):
with your witness.
Tom Hagy (11:31):
Yeah yeah, the impressions that humans give on
other humans is like they sayit's within the first few
seconds.
So you, I, I, somebody oftensay oh, I feel bad for that guy,
Look at it?
Elizabeth Larrick (11:41):
Oh yeah, absolutely, and that's what we,
you know we ask them.
You know what question wouldyou, would you want to ask this
witness?
And I've had them come back andsay like I wouldn't ask that
guy anything.
He's never going to tell thetruth.
Tom Hagy (11:51):
Right, right, there you go.
Yeah, I saw, yeah, the twopolished thing could come up.
We had invited jurors to aconference of trial lawyers once
and they were from an actualcase and one of the lawyers was
there on the panel and one ofthe jurors I mean they, they're
not trying to impress anybody,they don't care.
They got there, we paid themsomething, they're, they're on
(12:11):
their way, they're going to losetheir jobs, and so the respect
they have for lawyers was it wasthey either did or didn't, but
anyway they, this guy came in,he's obviously fit, he's got his
thousand dollar suit on andhe's you know, uh, this watch
obviously was a rolex and allthis stuff, and the lawyer is
sitting there.
So I didn't want to hear fromhim, I didn't trust him, and the
lawyer is just sitting thererubbing his head.
(12:33):
It's like you know, here I amtrying to look professional and
and it's really it's workingagainst me yeah, and it's.
Elizabeth Larrick (12:41):
it is so amazing, having done as many
trials as I have, like thatlawyers will still kind of go
out of their way sometimes to beflashy, and I'm like you are
thinking yourself here like youdon't need the fancy socks like
or you know, or you're, you gota subtle tie that's got stuff on
it.
It's like you know, just Ithink it's funny.
You went tie, that's got stuffon it.
Tom Hagy (13:04):
It's like you know just, I think it's funny, you
went right to the socks.
Elizabeth Larrick (13:06):
I did I did.
Has that?
Has that come up before?
Yes, it has, they're like oh,really okay yeah, I was a lawyer
and he was, uh, he had on areally expensive pair of nikes,
which was unusual and then thesebright orange socks and I was
just like what, what?
What are we doing here, man?
Tom Hagy (13:22):
You know, yeah, all right.
Well, there's a key takeawayright there.
Elizabeth Larrick (13:26):
That's right.
That's right.
Please watch your socks.
Tom Hagy (13:29):
And you should wear them also, I think.
Elizabeth Larrick (13:31):
Oh yeah, well , yes, that's also very
important.
Tom Hagy (13:35):
So you've tested other credibility in other contexts.
You had mentioned Lisa.
You talked about discrimination.
What else did you have?
Did you have a PI case?
Elizabeth Larrick (13:44):
Yeah, a personal injury case.
You know, occasionally peoplewill get tripped up on our Fifth
Amendment right when it's likethere could be a place where
somebody should take it, butwhat does the jury think about
it?
And so you know we had hererecently where we tested both
ways right, where in one focusgroup he took the fifth.
In another focus group he justtold what happened and the gap
(14:08):
of imagination that allowedthose people to create the worst
case scenario was really like,oh my gosh, we really have to
now dig deep and figure out ifhe needs to take the fifth,
because it could really end uphurting his credibility.
Tom Hagy (14:23):
Right, sure, yeah, I can see where that.
Yeah, people make thatassumption.
Why would?
Why would you take it if youdon't have to?
Elizabeth Larrick (14:30):
And sometimes people don't penalize them,
like they're like, absolutely,if that's my right, like I'm not
gonna.
You know I'm not going to gettripped up by that, but I think,
because of the scenario of thiscase, where there was just this
giant gap of information,nobody was telling what happened
in this particular evening andso then it became okay, well,
(14:51):
you have the information andyou're not telling us.
You know versus just like youknow, were you drinking that
night?
I take the fifth.
You know?
Something simple like that.
Tom Hagy (14:58):
Yeah, that makes sense .
So, um yeah, so yeah, I'mjumping around a little, so
you'll just, you'll just.
Elizabeth Larrick (15:05):
I'll flow you go, just flow.
Tom Hagy (15:09):
So what about?
Because a lot of lawyers wantto know certainly what the value
of their case is, and assessingdamages, I don't know, maybe it
would help with settlement orsomething.
So what?
How does this?
Have you had experience withthat?
How does it work?
Elizabeth Larrick (15:23):
Yeah, that is like one of the number one
questions I get all the time islike well, they tell me how much
it's worth and I say, yes, butit's not really reliable.
It's just eight to 10 people.
I mean, there are other toolsout there that can really get
you much closer.
When you do like a big datastudy that's got 2,000, 3,000,
(15:43):
4,000 inputs, then you reallycan statistically come back down
to what would be.
But with these eight to 10people, what's more important is
just testing.
What is the information thatyou have?
A lot of times people rely onlife care plans.
Right, that put together howmuch people are going to need
(16:03):
for care and householdmodifications and medications
for the rest of their lives.
And it's fascinating to havejust testing that kind of
information, because we are, ashumans, programmed to focus on
the present right now.
Well, I will worry about thefuture later.
Like what's how?
You know that'll take care ofitself, and so it's very like
(16:26):
it's interesting and lawyerstake a lot for granted to think,
oh well, I put this together,we got a great doctor's going to
get up there, and I'm alwayslike, yeah, you need to test it
though, because you couldtotally lose a bunch of
credibility If you know they'resaying this guy needs a ramp and
he needs all these things andthen the guy lives in a house
with like a flight of stairs.
Yeah Right, yeah, they're goingto put that together real
(16:49):
quickly.
So you know, some of thoselittle things of testing like
the credibility of it and andputting together the story of
the damages itself is sometimespretty precarious if you don't
have enough before and afterwitnesses or just relying on,
like maybe a spouse or a child.
You know there's a little bitof credibility there.
(17:11):
So it's helpful just to havethose pieces tested to make sure
we're good or we're missing onstuff.
And going back to those videos,you know one of the coolest
focus groups I've done hererecently was an older gentleman
had a traumatic brain injury andno doubt I mean got hit right
(17:33):
on the noggin.
You know we can't dispute that.
But what was cool was hisdaughters had taken videos of
him with his grandkids beforeand then after, and it was night
and day.
And the focus group was like wewere so glad we had those 30
second clips of him, you know,playing whack-a-mole with the,
with the little kid, or holdingthe baby, and then afterwards
(17:55):
like there's just you know yeahcan't do any of that.
So it's it, do any of that.
So it's amazing, like thelittle things that we may have
in our lives that really helpjurors understand damages.
Tom Hagy (18:06):
Yeah, so you're using images, tell a story and you're
presenting evidence.
So for lawyers who want to usethis, can you help them craft
the sequence of events intelling these stories?
Elizabeth Larrick (18:22):
Yes, yeah, I mean I think with focus groups
they really tell you thesequence you need, because we'll
, we'll, you know, fashion thestory one way and then come back
and do it in a different way tosee which way hits them.
But yeah, from a from astandpoint of brain science and
like primacy, what are we sayingfirst, recency, what are we
(18:43):
saying you know last, but howare we helping create the story
that we have to be veryconscious of organizing it,
otherwise it's just mass chaosin their minds, it's just
confusion.
Tom Hagy (18:52):
Right.
Yeah, it's just kind of a firehose, that's right.
Look at all the stuff I'vegathered.
Now I will blast it at you.
So have you had examples where,leading up to trial, that the
focus group has shifted causedthe lawyer to want to shift
their strategy?
Elizabeth Larrick (19:11):
Absolutely, absolutely.
We recently tested a case.
They were right on the doorstepof within 30 days.
They were coming up and theyhad, I would say, probably three
, what they considered keyviolations by the defendant.
And there were more, but theythought these three, these were
(19:31):
the most important violations.
And we put it to a focus groupand tested it and it came back.
They had one right, but theyhad two others that were a lot
stronger.
So what we did was we took thatinformation, we rearranged
their opening to focus on thosetop three and then took the rest
though we didn't ditch it, weput it into cross-exam and then
(19:54):
in closing, he was able to saywe prove these three things, but
then we also prove these otherthree.
So they had you know more ontheir list of things they proved
, but then we also prove theseother three.
So they had you know more ontheir list of things they prove.
But it became super importantto just focus on those three for
opening instead of trying togive them all six.
Tom Hagy (20:11):
Yeah.
Elizabeth Larrick (20:12):
And prioritize it in order of like
first in time.
Tom Hagy (20:16):
Yep, I gotcha, yeah yeah.
The sequence I'm telling astory is obviously critical to
how effective it is, how peoplereceive it and remember it, and
so you've mentioned a couple oftimes you know people love
videos.
How are you able to effectivelypresent demonstrative evidence,
(20:37):
pictures, other things thatpeople can look at and engage
their reaction to those things?
Elizabeth Larrick (20:44):
Absolutely.
I have a good relationship witha medical illustrationist and
she works with another lawyerthat we do a lot of focus groups
and we will just put thoseimages up.
What makes sense?
Does it look bad?
Could you gather all?
You gather all these injuries?
Or maybe it's too much.
So those are also really easy,quick ways where it's just you
(21:06):
know show them the picture andkind of ask them what's injured.
You know, because sometimespeople will say you'll have a
group of people that get it andthen you'll have a group of
people who are like I need youto walk me through this.
So there's always a littlebalance.
I think for everybody who'ssitting on the jury you need to
have a nice balance.
But sometimes you get thesemedical illustrations and
there's 50 words on the side ofthe image and they're like I
(21:30):
can't even pronounce that.
Tom Hagy (21:31):
I'm like.
I can't either, so take it offSome of the animations I mean, I
haven't seen any even recently,but they used to be some of
them were just so incredible.
You know 3d animation, Iimagine now, with animation and
AI and things, they must be ableto create some incredible.
You could turn people intobabies, for example, babies that
(21:56):
have an unusual amount of teeth.
That's right.
Elizabeth Larrick (21:59):
Yes, I, I definitely.
Tom Hagy (22:00):
I have seen that recently you've seen that what
kind of a bizarre person wouldmake a baby of themselves with
teeth?
That's just so strange.
Have you seen?
This is a complete sidetrack.
Of course we're talking aboutyou, but um, we have you.
Have you seen?
There's a clip where, uh, ahusband it looks like he's
coming home from work he'sdragging there's a baby in the
(22:21):
high chair and mom had paintedeyebrows on the baby.
It's, yeah, it's the best, okay, um making fun of babies.
Elizabeth Larrick (22:30):
I mean it's hilarious.
Tom Hagy (22:33):
Yeah, yeah.
I don't know why babies are sofunny.
You know, just a very basiclevel where?
Where are these people when,when you're doing this?
So they just sitting at home,or they you know the grocery
store?
What?
Where are these people whenyou're doing this?
Are they just sitting at home?
Are they, you know, at thegrocery store?
How are you setting it up?
Elizabeth Larrick (22:46):
We don't let them do grocery store.
We, you know, we obviously haveto set some rules up.
They can't be driving in a car,they can't even be a passenger
in a car and, trust me, I've hadpeople show up on the bus and
I'm like this not gonna workright, so uh, so yeah, we have a
little bit of rules, but mostof the time they're showing up
at their kitchen table, or wedefinitely have people who show
up sitting in their bed and yeah, yeah you know, we, just you
(23:10):
know, we have a few lightingrequirements and things like
that, and you know, please trynot to smoke.
But you know again, the morerelaxed people are, the better
feedback you get try, try not tosmoke.
Tom Hagy (23:22):
I think that's a good tip.
I think for anybody on Zoomit's like you must when they do
that you just take it to blackand white and it'll look like a
talk show from the early 60sbecause everybody was smoking.
So are there any likemisconceptions that people would
have about this?
When you approach lawyers, Tellme what that conversation is
(23:43):
like.
Elizabeth Larrick (23:44):
I think one.
Most people are like whoa,you're using Zoom to do this?
I never would have thoughtabout that.
Like absolutely using Zoom.
People have a misconception thatthese are giant six-hour Zoom
mock juries and they're just not.
I mean, these are like you said.
They're issue spotting, they'refinding our weaknesses, they're
(24:06):
quick check-ins to see and getan outside perspective and, um,
you know, they're not intendedto replace a mock jury, but
they're intended to you be ableto get an?
Um, a look at what the jurorsthink before you begin discovery
, after you take that majordeposition.
Did you score all the berriesin the bucket or was it just you
(24:27):
, you know, bravado, thinkingyou got the, you got the person.
So, and I would just think mostpeople when I tell them you can
do this, you, somebody in youroffice, can learn to do this
that there generally is like ohwell, you know what if we do it
wrong, right.
Most of the time I'm like, ohwell, you know what if we do it
wrong, right.
Most of the time I'm likeyou're still going to learn
something, even if you do itwrong?
Tom Hagy (24:45):
Yeah, you've learned that you need to learn how to
use Zoom.
Elizabeth Larrick (24:48):
That's right, or you know, have somebody else
do it, because you argue witheverybody yeah.
It's always a goodcommunication skills at all
levels when you're doing theseas a lawyer.
Tom Hagy (25:02):
So are lawyers also presenting on these?
Of course they are, yeah, so oh, that must be great education
for them.
Elizabeth Larrick (25:10):
I I always hope that people see that
there's a lot of value in justgetting up and presenting to a
group of strangers who, like,they'll look at you, get a third
head, or they'll tell you likethat's dumb, Like yeah, yeah.
Tom Hagy (25:29):
So as as as a podcaster who I only thought I
was going to be doing audio, uh,when I started doing video, I
came to realize, my God, I makea lot of faces.
I, I, I'm paying attention toevery word, but sometimes I'm
like my eyes are doing things Idon't even know about.
I'm looking in different.
I mean it's like just payattention, man, you know, just
focus.
Elizabeth Larrick (25:46):
It's it.
You don't you underestimate howmuch you move and your
mannerisms, and very few peoplenaturally have that.
Not going to move, affect thetotal skill.
When, when people say affectlike a total skill, when people
say, oh, that's just natural,I'm like no, it's not.
(26:07):
Trust me, I have seen the bestof the best and it is a hundred
percent a skill you have topractice.
Tom Hagy (26:12):
Yeah, I first found out about it from my wife
because we would haveconversations and she would say
things and I think I'm justlistening and she's saying why
are you making that face?
I'm like I'm just listening toyou saying what, what's?
Why are you making that face?
I'm like I'm not, I'm not, I'mnot making you.
You clearly don't want to dothis or you don't like this
person.
I'm like, no, what are youtalking about then?
I didn't.
I see myself on here.
I'm doing this like oh yeah, Ithink I have a very expressive
(26:36):
face, so I have to like pokerface it like you.
Yeah, there's a fine linebetween looking psycho though.
You know what I mean.
You don't want to just like yeah, you got to get the nod, the
journalist nod, and then yes,they're very good at that on
like the daily shows and thingslike that, where they mimic
reporters.
They're like they're listeningwhile they wait.
Are the um?
(26:57):
Are the people you pull in?
Like I wonder, are you able totest, like different
jurisdictions, or that would beinteresting to me.
It's like, ok, well, we'regoing to, maybe we're going to
do this, try this in the city, Idon't know Houston or whatever,
but maybe Beaumont or maybePort Arthur.
Yeah, I'm showing off by allthe different towns.
Elizabeth Larrick (27:16):
You are, look at you.
Tom Hagy (27:17):
Yeah, yeah, but because the different jury polls
are going to be different.
Elizabeth Larrick (27:23):
You ever use it that way.
Yeah, absolutely, absolutelyCool.
Yeah, we tried to do as as muchas we can.
We try to make.
Uh, if people want veryspecific like we have to have
all people from Port Arthur uh,generally I say like okay, well,
let's, let's get a little bitwider, cause, guess what.
It's okay if somebody you knowis in Pasadena or you know like
30 miles down the road.
We're not going to be toodifferent.
(27:43):
But I'm not going to put you aDallas person in there, you know
.
But we have general groupswhere it's just generally Texas,
oklahoma, where that's going tobe fine for the majority of
issue spotting or weaknesses andstrengths.
Tom Hagy (27:56):
Yeah, yeah.
It would just be so fascinatingto test different parts of the
country too.
I mean, I don't know, youprobably haven't had to do that,
but I don't know.
It's just interesting for me,like, how does a New Yorker see
something versus somebody fromOklahoma City or something?
Elizabeth Larrick (28:12):
Well, we did some testing for some folks that
were going to trial and theywere very similar cases, but one
was in Seattle and one was inSouth Dakota.
So we ran the exact samepresentation but in two
different places and it wasfascinating how they had
similarities but then they hadcomplete differences on how they
(28:33):
thought about these bigtrucking companies.
Tom Hagy (28:35):
Yeah, I'll bet they did.
Yeah, that's interesting.
Yeah, going to different partsof the country, I was going to
say something political, but uh,I won't.
No, just no.
Just because, um, just just sayI think, uh, politically, I
felt like I was in one spot onthe spectrum until I went to
portland oregon and I found out,oh, I'm really not that far off
(28:57):
, I'm not that far from centeras I thought.
Elizabeth Larrick (29:01):
All about context, all about context.
Tom Hagy (29:03):
Wow, I was blown away.
I was like because I leanliberal, I should say that.
And then I went out there and Ithought, oh wow, I can see why
people find us annoying.
Sorry, I'll probably cut thatwhen conversations start off
with I don't know how you feelabout the police.
(29:24):
I'm like well, I feel largelypretty good about the police.
Elizabeth Larrick (29:37):
Okay, I'm going to cut that fascinating
and listening to people.
And because news used to stick.
News stories would stick andpeople would talk about it.
But the news, information,travels so fast that things just
don't even stick anymore.
And so my example that is herein Austin we had an Amazon truck
(30:00):
that, for whatever reason, wentoff the rails, not paying
attention, end up running into,think, 10 or different cars,
killed five people instantly,and it was on the news for, you
know, days and days and days anddays.
Well, shortly thereafter, I hada focus group and I know it made
national news.
(30:20):
But we had a focus group just inSan Antonio, not a peep, and we
had we were doing a case withAmazon involved and I was just
like, how is it that this is notnobody brought this up?
But it happens more often thatyou think that we lawyers think,
oh well, that's going to be topof mind, that's going to be
something people are going to bethinking about, and I have to
tell them, like it's not,because you pick up your phone,
(30:43):
you're in a whole differentworld.
You put your phone back down.
Like you know, we have so muchinformation that rushes at us
that, as lawyers, we reallycan't rely on.
Oh, people are going to bethinking about that.
We really have to be veryconscious and focused about what
we give people to think, abouthow we organize it, because
(31:05):
while we think people may havegrasped that story or grasp the
importance of having rules forlike, they don't, it just goes
in one ear and out the other soit's definitely one of those
observations that I've seen, andalso people you know always ask
me, well, what about politicalaffiliation?
And in the past few years I cantell you like always ask me,
(31:25):
well, what about politicalaffiliation?
And in the past few years I cantell you like that is just not
a moniker of trying to figureout who the juror is for you or
is not for you, Because you askpeople they don't know either.
They're guessing right.
You may ask somebody who theyvoted for, but that doesn't
necessarily at all translateinto what we used to or what the
science, the jury science, usedto be was oh well, if you're
(31:47):
red, then we're, then you'regoing for this, or if you're
blue, I mean, it's just like.
No, it's, it's out the windowright now and it's not anything
that when I people ask me, I'mlike please don't rely on that.
Like yeah people just don't knowand they're just as confused as
we are about it.
So it's not a way to, like youknow, put somebody in a camp of
a yes or no for your case.
Tom Hagy (32:07):
Texas.
Also, tara Trask.
I don't know if you know her,but she she was talking about
how people and she's doing juryselection, how differently
(32:29):
people are consuming their newsand how the news is influencing
their opinions of of experts.
Elizabeth Larrick (32:37):
Well, so, fascinatingly, people I think
it's like it's an unnormalamount of people are getting
their news from social media.
And lawyers think, well, that'sthe question I need.
But you have to go deeper thanthat.
Because it's like what socialmedia?
Because you know, if 50% ofadults are consuming their news
(32:57):
on social media, but which is it?
Because TikTok, unfortunately,is a lot of people's news source
.
But then the crazier thing islike people that are following
or getting their news fromsocial media are following like
news promoters, not actual newschannels or actual journalists.
So it's very skewed and it'skind of all over the board.
(33:21):
So when people ask it used tobe a very popular question well,
how do you get your news?
But now it's like, okay, well,what's what social media channel
is it?
And you know how?
How do we draw conclusions fromthat?
Well, I mean, it's just thatthe news is very skewed, yeah,
yeah.
What you're watching.
Tom Hagy (33:46):
Yeah, it is, and I'm, I mean I'm, I'm a trained
journalist and you know, andI've, uh, and I mean I and I
watch the news.
I, I love social media.
I get a kick out of it.
I follow comedians and, um, Ilove, I'm a drummer.
I love drummers.
I see how, I see what aterrible drummer I am.
But I also look, look for newsand sometimes I'm just I'm, I'm,
I'm appalled at how twistedsome stories are.
(34:07):
Or they'll put up a screamingcaption.
It's so funny.
And recently I um, you seetestimony and you know,
different outlets will say lookhow this guy, you know,
destroyed this witness, and thenlook how this witness destroyed
the Senator and his same clipand, um, and some of them are
like it's clips from you don'teven know when they're from like
(34:30):
when did this happen?
What, what, what did it happen?
Then you look even closer andit's like, oh, this is AI, this
isn't even.
I mean, you know so and I'msupposedly trained in this.
Uh, I don't know, I don't know.
I worry about what people arebeing trained or being how
they're being educated.
Elizabeth Larrick (34:48):
Yeah, yes, and that's why I said like now,
I mean not, you know, definitelymore than ever, but yeah, now
it is so vital and important for, as lawyers standing up in the
courtroom with jurors, to benumber one teachers, because we
have to, well, one, do the juryresearch to figure out what the
(35:09):
attitudes are, what are you upagainst?
And then number two, to come inand understand like it's.
You know it's.
It's a mile wide but an inchdeep.
People don't know unlessthey're have had their specific
life experience, which is thesame as the case, which is
really rare, you know, reallystanding up and putting your
teacher hat on in a way to helpthem come to the education they
(35:29):
need to to then make decisionsin the case.
Tom Hagy (35:32):
Yeah, yeah, that's good advice, just educating them
Also without making them feelstupid.
Elizabeth Larrick (35:40):
What a challenge for most lawyers.
I kid, I kid, I love all thelawyers I know you do, so do I?
Tom Hagy (35:48):
I have loved them for over 40 years.
I'm often the guy defendinglawyers.
You know I'm a lawyer.
I'm like, oh God, please don'tdo that.
A lawyer is the person you'regoing to want when things really
hit the fan for you, personyou're going to want when you
are, when things really hit thefan for you and 99.9% of them
are just awesome, just trying tomake a living, trying to do the
(36:09):
right thing and, yes, of course, so you use it to also help
people pick jurors, I guess, orget an idea of, maybe, what kind
of jurors they want.
Is that something you do?
Elizabeth Larrick (36:17):
Yeah, Sometimes I think if you're
going to do that you have to doseveral, like you have to do
quite a few to be able to kindof put all that information
together.
But a lot of times what we'redoing is we're getting people
just to practice, and hearingreactions to your questions and
being able to navigate.
I mean that is a huge skill inand of itself for jury selection
(36:38):
.
Tom Hagy (36:39):
Yeah, very cool, all right.
Well, I really appreciate it.
Elizabeth Larrick (36:50):
Yeah very cool, all right.
Well, I really appreciate it.
Any final thought you want togive somebody, if you had like
30 seconds to say why you shouldtry this, why you should do a
focus group by Zoom, is mindblowing and inspire so many
ideas and creativity for trial,beyond what you and your team
can come up with because you'rein that box.
They're in a whole other boxand if you can spend an hour or
(37:11):
two hours with folks and learnthree or four things that will
take your case to the next level, just do it.
It's very inexpensive, it'seasy to do.
I've got lots of resources onmy website, two really large
blogs.
I've done podcast episodesabout it and even offer free
webinars that are once in awhile for lawyers to learn how
to do it.
Tom Hagy (37:31):
Okay, good, maybe we'll do another podcast and
then we can have focus groupfolks watch and judge me.
Elizabeth Larrick (37:39):
Okay, I mean, if you want that, I mean.
Tom Hagy (37:46):
okay, I just want, I mean, if you want that, I mean
most lawyers do not do not wantto do that, they are not into
that.
I would think it'd be anawesome service for an associate
you know to get on and do this.
I just think it would be agreat service for them.
So, elizabeth larick, thank youvery much for talking with me
today.
Elizabeth Larrick (37:57):
It was a pleasure oh, thank you so much
for having me.
I really enjoyed my time.
Tom Hagy (38:05):
Yeah, this is helpful.
So I'll go through this andsend it to you and if you tell
me, you know you were extremelyarticulate.
I didn't hear anything thatyou'd be embarrassed by.
Elizabeth Larrick (38:18):
It's okay if it's in there.
I do all my own stunts, so whenI see something that sucks, I'm
like I'm it's in there.
Tom Hagy (38:23):
I do all my own stunts , so when.
Elizabeth Larrick (38:23):
I see something that sucks, I'm like
I'm leaving that in there.
Tom Hagy (38:25):
The Emerging Litigation Podcast is a
production of Critical LegalContent which owns the awesome
brand HB Litigation.
Critical Legal Content is acompany I founded in 2012.
That was a long time ago.
What we do is simple we createcontent that's critical on legal
topics for law firms and legalservice providers.
I believe we even have a catchytagline, which is your legal
(38:48):
content marketing department.
That kind of content can beblogs, papers, they can be
podcasts, webinars and we have agood time doing it and S4HB
litigation.
Well, that's the name underwhich we publish interesting at
least interesting to me legalnews items, webinars, articles,
guest articles, all on emerginglitigation topics.
(39:08):
That's what we do.
Once again, I'm Tom Hagee withCritical Legal Content, nhb
Litigation.
If you like what you hear andyou want to participate, give me
a shout.
My contact information is inthe show notes.
Thanks for listening.
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