Here's a portion of the first three paragraphs of the preface to David Ball on Damages, which makes a point that's driven home throughout the book:
Over the past few years at my damages seminars, I have asked thousands of personal injury attorneys, "How many of you tell jurors that preponderance applies not only to liability but also to verdict size?" Fewer than 2% raise their hands. Traditionally, plaintiff's attorneys have thought so little about damages that they have not mentioned the burden for decision making about money.
As a result, a common juror comment in deliberation is, "Well, I'm just not completely convinced that the verdict should be $________. They didn't absolutely prove it." Not even the most favorable plaintiff's jurors argue with that, because they don't know they should and they don't know how.
This failure is a perfect example of how attorneys ignore damages.
Even if you don't own the book, these paragraphs will give you a little something to incorporate into your next trial.
Related post: "An Example of the Use of Demonstrative Evidence in a Modern Case."