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In closing a long trial, attorneys face the high hurdle of convincingly spotlighting the most important evidence jurors have heard across weeks of testimony. In a school shooting trial that ultimately stretched across five weeks, Daniel Rodriguez’s closing on liability adeptly led jurors along a timeline of evidence that helped deliver a seven-figure verdict.
Bowe Cleveland, a Taft Union High School student was shot in the chest by fellow student Bryan Oliver. Cleveland, represented by Rodriguez, of Rodriguez & Associates, claimed school administrators failed to act on Oliver’s history of worrisome behavior, including threats to other students.
The 14-day trial, which was bifurcated into liability and damages phases, featured extensive school records made on Oliver over the course of more than a year. In closings of the liability phase, Rodriguez used a two-paneled timeline to simplify the potentially overwhelming amount of information given to jurors, while emphasizing the weight of evidence the district had concerning Oliver's behavior.
The boards, though filled with information, detail only what Rodriguez say is the most important evidence he argues should have led administrators to more effective action.
“And for each one of these, I have evidence to back it up,” Rodriguez says, emphasizing the weight of proof he argues supports his case.
Throughout his closing, Rodriguez moves between the boards and the evidence itself that details Oliver’s alleged “red flags.”
For example, in recounting a staff member’s record of a conversation with Oliver, highlighted on the board as an early indicator of the student’s issues, Rodriguez reads from a record: “‘The conversation was very disturbing and stressful. I am very concerned for the safety of the students and staff, as well as Bryan.”
Rodriguez skillfully takes jurors on a journey through the timeline, detailing the evidence as he leads through the months of conduct leading up to the shooting. The technique is simple yet effective in breaking down the massive amount of evidence jurors have heard. And it helped set the stage for a $3.8 million verdict.
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