Building Your Case Around Jury Instructions
Graduated with honors from both Davidson College and the University of Miami School of Law.
Allen Bonner runs a solo appellate practice, South Florida Appeals, which focuses on civil cases of all sorts, including personal injury, wrongful death, product defect, commercial contract, class action, and insurance and bad faith disputes.
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Program Summary
Jury instructions are often neglected until close to the time of trial. But they are critical for the successful development of any case through appropriate pleading and discovery. It is essential at the beginning of your case to understand as far as possible how the jury will ultimately be instructed, so that you can fashion your pleadings to address the jury instructions and verdict form, draft discovery requests directed to the issues for the jury’s consideration, ask questions of deponents that will elicit critical admissions that fit within the ambit of the jury instructions and issues for the jury’s consideration on the verdict form in your case, and eventually present a closing argument that fits – hand in glove – with the jury instructions for your case.
Key topics to be discussed:
- How to identify the jury instructions for your case
- How to address the jury instructions in your pleadings
- How to draft discovery requests to fit your jury instructions
- How to take depositions with a view towards your jury instructions and verdict form
- How to incorporate your jury instructions into opening statement and closing argument to highlight how your evidence proves the elements of your claim on the verdict form
Closed-captioning available
Speakers
Christopher M. Drury | Drury Law Firm
Graduated with honors from both Davidson College and the University of Miami School of Law. Chris is a member of The Florida Bar, the South Carolina Bar, and the Law Society of England and Wales. In 2022, Chris served as President of the Miami-Dade Trial Lawyers Association. Chris has handled complex personal injury and commercial cases in state and federal court in multiple jurisdictions. Chris focuses his practice on the prosecution of serious personal injury cases, as well as complex business and commercial disputes, including class actions. Chris has helped clients obtain multi-million dollar recoveries in personal injury and wrongful death cases, business litigation, and securities litigation, as well as a multi-million dollar jury verdict in a maritime personal injury case, a multi-million dollar jury verdict in a rollover motor vehicle crash case, a multi-million dollar jury verdict in a motorcycle crash case, and a multi-million dollar verdict in a car vs. pedestrian case.
Chris has prosecuted multiple catastrophic personal injury cases resulting in 8-figure recoveries, including a boating accident case culminating in a court-approved $12,000,000.00 settlement for a father and son. Chris is a Life Member in the “Multi-Million Dollar Advocates Forum”. Chris was named to the Florida Super Lawyers list by Super Lawyers in 2021, 2022 and 2023. Chris was recognized by Florida Trend magazine as a Florida Legal Elite Winner in the area of Civil Trial in 2018, 2019 and 2020. Chris was named to the Florida Rising Stars list by Super Lawyers for 2014, 2015, 2016, and 2017. Chris was recognized as one the top “40 Under 40 Outstanding Lawyers of South Florida” by the Cystic Fibrosis Foundation in 2015. Chris was invited to become a member of “The National Trial Lawyers: Top 40 under 40” in 2014, and then a member of “The National Trial Lawyers: Top 100 Civil Plaintiff” in 2017, as well as every year thereafter. Chris was recognized by Florida Trend magazine as a 2014 Florida Legal Elite “Up and Comer” in the area of Civil Trial. Chris also enjoys a wealth of experience in the defense of a wide variety of banking and insurance-related matters. Chris speaks Spanish and German fluently.
Allen Bonner | South Florida Appeals
Allen Bonner runs a solo appellate practice, South Florida Appeals, which focuses on civil cases of all sorts, including personal injury, wrongful death, product defect, commercial contract, class action, and insurance and bad faith disputes. His work has been instrumental in recovering tens of millions of dollars for plaintiffs in South Florida, and it includes successful appeals against Miami-area municipalities and construction companies, national product manufacturers, and insurance companies of all sorts.
Allen’s recent decisions have upheld Constitutional jurisdictional limits to defeat million dollar fee claim; preserved a punitive damages order against collateral attack; and fended off challenges to class certification multimillion-dollar product/construction defect claim.
Before transitioning to appeals, Allen first- or second- chaired approximately 25 trials at the Miami-Dade Public Defender’s Office and at Ver Ploeg & Lumpkin (now Ver Ploeg & Marino). He next joined Colson Hicks Eidson, eventually becoming partner and leading the firm’s appellate division.
In addition to being a former board member for the Miami Dade Trial Lawyers Association, Allen co-chairs the Miami Dade Bar’s Appellate Courts Committee and the Florida Bar Appellate Practice Section’s monthly webinar programming series. He’s presented or moderated more than a dozen CLE courses and has been published in the University of Miami Law Review, the ABA Appellate Practice Journal, and on the ABA’s “Sound Advice” podcast series. Allen graduated from Brown University magna cum laude and from Columbia University’s School of Law as a Harlen Fisk Stone Scholar, Charles Evans Hughes Fellow, and Jacob Berger Fellow. He also studied at Oxford University, England. He is licensed to practice law in Florida, Georgia, and the District of Columbia.
Agenda
I. How to identify the jury instructions for your case | 2:00 pm – 2:20 pm
II. How to address the jury instructions in your pleadings | 2:20 pm – 2:40 pm
III. How to draft discovery requests to fit your jury instructions | 2:40 pm – 3:00 pm
Break | 3:00 pm – 3:10 pm
IV. How to take depositions with a view towards your jury instructions and verdict form | 3:10 pm – 3:40 pm
V. How to incorporate your jury instructions into opening statement and closing argument to highlight how your evidence proves the elements of your claim on the verdict form | 3:40 pm – 4:10 pm
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- All CLE webinars broadcasted in last 12 months
- Programs covering over 35 practice areas
- Hot topics & changes in the law
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