"It may seem perfectly understandable for the plaintiff as the witness to complain with a whole litany of 'he/she/
What do jurors prefer? "Plaintiffs who, despite their misfortunes, are valiant, are giving it their best shot to overcome adversity," explains Nelson. "This doesn’t mean your plaintiff clients must develop a stiff upper lip and through gritted teeth maintain 'All is well,' but rather that you make sure during direct that you expose the ways in which your clients did the best they could to survive, heal or improve things despite horrendous odds. That's what impresses jurors. Now you have a potential winner in juror eyes, not a loser-whiner."
For more trial techniques, go to Nelson's blog, "A Winning Tip," http://awinningtip.blogspot.com, or for her articles and books, http://www.noellenelson.com/