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New Jersey Trial Evidence and Procedure

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Andrew J. Kyreakakis


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New Jersey Trial Evidence and Procedure provides a practical and comprehensive presentation of trial evidence and procedure. This book encompasses the rules and law governing the trial of cases which are found in the evidence rules, court rules, court decisions, and Model Civil Jury Charges. This volume also provides important practice points and insights as to how this body of evidence law plays out in a courtroom and what strategies provide maximum success. 


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  • Availability: Available
  • Brand: New Jersey Law Journal
  • Product Type: Books
  • Page Count: 762
  • ISBN: 978-1-62881-614-3
  • Pub#/SKU#: JEVID20
  • Pub Date: 06/28/2019
  • Volume(s): 1
  • Frequency: Annually

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Andrew J. Kyreakakis is a member of the New Jersey and New York bars and is a partner in the litigation department of Weiner Lesniak LLP law firm. Previous to this he has been a certified civil trial attorney in New Jersey for more than 15 years.  Kyreakakis is the attorney of record on numerous state and federal decisions, including opinions on trial evidence and procedure, specifically expert testimony, motion for directed verdict, evidence on settlement negotiations, impeachment, prejudicial evidence, remittitur, motion for a new trial, and parol evidence. 


Chapter 1: Pretrial Information Exchange.... 1

Chapter 2: Selecting a Jury.... 9

Chapter 3: Jury Note Taking and Jury Questions.... 35

Chapter 4: Opening Statement.... 41

Chapter 5: Preliminary Hearing.... 47

Chapter 6: Conditional Evidence.... 53

Chapter 7: Judicial Notice.... 55

Chapter 8: Presumptions.... 65

Chapter 9: Relevance, Exclusionary Rules and Limiting Instructions.... 77

Chapter 10: Character Evidence.... 91

Chapter 11: Privileges.... 119

Chapter 12: Lack of Personal Knowledge.... 161

Chapter 13: Order of Interrogation and Presentation of Proofs.... 165

Chapter 14: Refreshing Recollection and Past Recollection Recorded.... 171

Chapter 15: Questioning and Calling of Witnesses by the Trial Judge.... 179

Chapter 16: Sequestration of Witnesses.... 183

Chapter 17: Attacking Credibility.... 187

Chapter 18: Prior Inconsistent Statement Used to Impeach the Witness.... 195

Chapter 19: Prior Inconsistent Statements Admitted for Their Truth.... 205

Chapter 20: Prior Consistent Statements and Vouching.... 209

Chapter 21: Expert Testimony.... 213

Chapter 22: Use of Depositions and Prior Testimony at Trial.... 289

Chapter 23: Use of Interrogatory Answers at Trial.... 323

Chapter 24: Hearsay.... 329

Chapter 25: Authenication of Trial Exhibits.... 373

Chapter 26: The Parol Evidence Rule.... 397

Chapter 27: Trial Objections.... 403

Chapter 28: Closing Statement.... 411

Chapter 29: Jury Charge and Verdict Sheet.... 421

Chapter 30: Trial Motions... 457

Chapter 31: Spoliation of Evidence.... 479

Chapter 32: Offer of Judgment.... 495

Table of Cases.... 513

Table of Rules, Statutes, and Jury Instructions.... 553

Index.... 559