How to Test Them in Advance
When presenting a personal injury case at trial, evidence is everything. The right exhibits can mean the difference between a lowball offer and complete compensation for the client.
At Sam Aguiar Injury Lawyers, we’ve honed the art of preparing compelling exhibits and testing them before trial to ensure they resonate with the jury. In this post, we’ll break down the most effective types of exhibits, how to test them before trial, and why these strategies lead to better verdicts.
Want a quick overview? Watch our video here:
Key Exhibits for Personal Injury Trials
Below are the most impactful trial exhibits that help tell a compelling story in court.
1. Medical Records Brought To Life Via Expert Testimony
Medical records are foundational evidence in any injury case. However, they can be dry and difficult for jurors to interpret—which is where expert testimony comes in.
Best Practices:
- Use medical illustrations and radiology imaging to show injuries visually.
- Have a doctor or specialist testify in simple terms.
- Create a timeline of medical treatment to demonstrate long-term impact.
Why It Matters:
Jurors are not doctors—helping them understand the severity of an injury is crucial in maximizing damages.
2. Accident Reconstruction Visualizations and Animations
Accident reconstructions provide a clear visual representation of how an injury occurred. These can be especially powerful in cases involving car crashes, truck accidents, or falls.
Best Practices:
- Use 3D animations to recreate the sequence of events.
- Combine expert analysis with visuals for maximum impact.
- Highlight key moments (e.g., when a truck has a hard brake, lane departure, jackknifed, or collides with another object).
Why It Matters:
A well-crafted accident reconstruction can make liability crystal clear for the jury.
3. Day-in-the-Life Videos
A day-in-the-life video is one of the most persuasive exhibits in a personal injury case. It shows how an injury affects a person’s daily life—something that words alone can’t fully capture.
Best Practices:
- Film the client performing routine tasks (e.g., getting out of bed, dressing, eating).
- Show struggles with mobility, pain, or limitations.
- Avoid overproduction—authenticity resonates more than a polished edit.
Why It Matters:
Jurors may intellectually understand an injury, but seeing the struggle makes it personal.
4. Economic Loss and Damages Charts
Jurors often struggle to grasp how much money a victim has lost due to an injury. Clear, easy-to-read charts make financial damages more tangible.
Best Practices:
- Include a breakdown of medical expenses, lost wages, and future care costs.
- Use simple visuals (e.g., bar charts, line graphs).
- Have an economist or financial expert explain long-term losses.
Why It Matters:
Numbers can feel abstract—visual charts make damages real and hard to dispute.
5. Pre-Trial Focus Groups: Testing Your Exhibits
Before going to trial, testing your exhibits ensures they resonate with the jury. We refine our presentation using mock juries, focus groups, and attorney feedback.
How to Test Effectively:
- Mock Trials – Present key exhibits to a focus group and measure reactions.
- Surveys & Feedback – Ask what parts were confusing, persuasive, or unnecessary.
- Jury Consultants – Work with experts to improve clarity and impact.
Why It Matters:
Even the best exhibits fall flat if they don’t connect with jurors. Pre-trial testing allows adjustments before it’s too late.
Frequently Asked Questions (FAQs)
1. What makes a personal injury case strong in trial?
A strong case is built on:
- Storytelling – the groundwork must be laid for jurors to assemble the story accurately.
- Honesty – jurors don’t want to find in favor of liars or exaggerators.
- Compelling visual exhibits – society expects it now.
- Expert witnesses – it is necessary to simplify complex issues.
- Resonation —jurors should feel the emotional impact.
2. How do day-in-the-life videos impact jury verdicts?
These videos humanize the victim and increase empathy. They give jurors a firsthand look at the daily struggles caused by an injury, often leading to higher settlements or verdicts.
3. Are accident reconstruction animations allowed in court?
Yes, so long as they pass pre-trial scrutiny. They must be based on scientific accuracy and have value that outweighs any prejudice to the other side. Courts tend to require:
- Expert validation (e.g., an accident deconstructionist showing supporting calculations, etc).
- No misleading elements (e.g., exaggerated sound effects, speed representations, etc).
- Consistency with other evidence (ECM data, GPS reports, cell phone location information, roadway markings).
4. How do pre-trial focus groups improve case outcomes?
Focus groups help:
- Identify which exhibits resonate the most.
- Expose gaps in the argument that need fixing.
- Provide insights into how jurors think and react.
Many top trial attorneys never enter a courtroom without testing exhibits first.
5. How can I ensure my personal injury lawyer is prepared for trial?
Ask your lawyer:
- Do you use focus groups to test exhibits?
- Have you won similar cases before?
- What types of trial exhibits do you typically use?
- Will we have expert witnesses to support our claims?
At Sam Aguiar Injury Lawyers, we prepare every litigated case as if it’s going to trial—because that’s how we get the best results.
Final Thoughts
Trial exhibits aren’t just “extras”—they’re powerful tools that can change the outcome of a case. The right mix of medical records, animations, videos, and focus group-tested visuals can distinguish between winning big or walking away with less than you deserve.
Watch our short video on trial exhibits here: