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Los Angeles, CA

Dear Sandy:

I again want to thank you and your firm for your invaluable advice and support during the Paul trial. The full range of your pretrial work, and the work throughout jury selection and trial, was done expertly and efficiently. Circumstances permitting,

I look forward to working with you in the future. I hope to see you soon.

   

Dear Sandy:

I would like to take this opportunity to thank you for your invaluable assistance, support and splendid organization system with the jury simulation in our Moreda case.

I most definitely look forward to working with you in the future on additional cases.

   

Dear Mr. Marks:

Thank you for providing assistance to me in regard to the two Benlate trials which I have recently concluded. Having worked with you on these two lengthy, complex trials, I would like to offer my thoughts in regard to the assistance you provided. First, I felt that the focus groups you set up for me were extremely helpful. The duPont Benlate litigation was, of course, extremely complicated. There were thousands of exhibits to choose from and many different themes which could be utilized in a case of this type. I felt that the focus groups were extremely helpful to me in that they assisted me in the selection of exhibits, the refining of my theories, and the orderly presentation of this very complex material. I also found it extremely helpful to be able to observe the feedback that we got from the focus group juries in that it gave me good insight into which theories would be embraced by the jury and also gave me increasing confidence in the strength of my case as we approached trial.

I was also extremely impressed by the shadow juries you provided me in the two trials themselves. I really think that shadow juries are the most useful trial innovation I have seen in many years. The opportunity to get daily feedback from a sitting jury is an asset which cannot be over-estimated. It gave me a great deal of assistance and a great deal of confidence to know when my theories were being adequately presented such that they were being understood by a group of lay persons. It gave me the opportunity to refine my trial strategy on a daily basis and also gave me immediate feedback as to the effectiveness of my opponents in their handling of witnesses. I did, in fact, make numerous decisions on the calling, or not calling, of witnesses based upon what I considered to be the very reliable feedback I was getting from the shadow jury as to the necessity of various elements of proof.

Above all, I was amazed at the accuracy with which the shadow juries predicted the verdict from the real jury. Both shadow juries came in with verdicts both as to liability and as to amount which were virtually identical to that of the real jury. Having seen this happen twice in a row, I now believe that shadow juries can also be an extremely efficient tool for making settlement decisions during the course of a trial because I believe that they do prove to be very accurate predictors of what the actual verdict will be.

I look forward to working with you again in the near future on upcoming cases.

   

Dear Sandy:

I want to thank you and your entire staff for the outstanding job you did in helping us get ready for the war.

The focus groups were very helpful and even the deposition reviews helped us realize we had to pare them down and tighten them up and we did all of those things.

Most importantly, however, was your continued interest and good will. We will always be grateful.

Another job well done. Best wishes.

   

Dear Sandy:

I want to express my gratitude for your assistance with our case. Maybe someday there will be a source of funds from which we can all be compensated. Even without it we did what we do.

Thank you for the Burden of Proof chart. By now you probably saw it being used on national television. I figured a way to do so without objection and while I surprised and severely angered the prosecution in doing it, they were caught flatfooted. All the courtroom observers thought it was a dramatic visual aid as do I. I look forward to using it in the future. Once again, thanks.

   

Dear Mr. Marks:

I would like to take this opportunity to thank you for your help in the above-referenced case.

Your assistance during the Voir Dire was invaluable. I believe our ability to select fair-minded jurors directly led to Officer Campbell's acquittal on the perjury charges.

In addition, your staff did a wonderful job in preparing officer Campbell for trial. As one of the jurors said after trial during an interview "we found her to be a very credible witness."

I look forward to using your services again.

   
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