C V N   D I S C O V E R Y

Fried Goldberg Attorneys Break Down the Closings That Won Their Big Verdicts

How to "arm the jury" to deliver the verdict you're looking for. 

Attorneys at Atlanta's Fried Goldberg have made headlines over the years for regularly winning 7 and 8-figure verdicts in cases ranging from trucking to premises liability.  And each of those wins was set up by strong closing arguments. 

Fried Goldberg attorneys Joseph Fried, Michael Goldberg, Brad Thomas, and Eric Rogers were featured on a CVN webinar highlighting the closing techniques that secured four of their verdicts, including:

  • A $25 million verdict, and an ultimate $18.75 million judgment, against the Metropolitan Atlanta Regional Transit Authority, or MARTA, for the brain damage a woman suffered in a fall from a paratransit bus.  — Johnson v. MARTA.

  • An $8 million verdict against a trucking company for the crash that injured a motorcyclist’s wrist and ankle. — Stevens v. JRK Trucking, et al. 

  • A $5 million verdict against a party rental company for the traumatic brain injury a teen suffered in a “bubble soccer” game. — Reyes-Quezada v. Game Truck of Georgia, LLC.

  • A $2.67 million verdict for the debilitating injuries a patient suffered in a fall from a hospital wheelchair. — Byrom v. Douglas Hospital, Inc.

The in-depth discussion, which features video from each of the trials, highlights their most important closing argument techniques, and illustrates how they can be used across a range of cases. 

Watch the full, two-and-a-half-hour webinar beginning to end by clicking on the play button below. Or, jump to specific topics in the webinar with our index. 

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Fried Goldberg Attorneys Detail "The Art of the Close"

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Joseph Fried

Joe Fried has been named Trucking Trial Lawyer of the Year in 2014 and 2015 by the American Association of Justice Trucking Litigation Group. A founder and one of the first-ever attorneys to hold board certification in truck accident law, Fried is a faculty member at the prestigious Gerry Spence Trial Lawyers College. Among his notable trial verdicts: a $25 million award for the brain damage a paratransit bus passenger suffered in a fall.



Michael Goldberg

Lead counsel on a dozen cases with verdicts exceeding one million dollars, Mike Goldberg is a two-time CVN Georgia Plaintiff’s Attorney of the Year honoree. His courtroom track record has earned him membership in the American College of Trial Lawyers. He is also the author of The Library of Personal Injury Forms, 3d Ed., and Understanding Motor Carrier Claims, 5th Ed. Goldberg spearheaded wins in each of the four trials the panel will discuss. 



Brad Thomas

Brad Thomas carries a two-decade trial history that includes record verdicts across numerous counties. He is AV Preeminent Peer Review rated by Martindale-Hubble. His trial wins include a $5 million verdict for the traumatic brain injury a teen suffered in a bubble soccer game.



Eric Rogers

Eric Rogers has been named to the Rising Stars list of Georgia Super Lawyers in 2014 and 2015. He has a history of trial wins that include a $3.5 million verdict for a woman injured when her car was rear-ended by an ambulance, and an $8 million verdict in a motorcycle crash case.



Topics in "The Art of the Close"

Click each topic below to skip directly to the discussion. 


The attorneys discuss how they view closings within the broader context of trial and detail the goal of their closings.  

What you'll learn:

  • Approaches to closing within the framework of the full trial. 
  • What may be the most important part of a close.   
  • Why shorter closings may be stronger for a case.

Quotable moment:

You better have earned the credibility that you need to take the case home, and you're arming the jury with the tools to go and do what you've been asking them from opening to do. Fried on closing argument.  

Explaining the right verdict for the right reason

Using video from two of his closing arguments, Goldberg leads a discussion on the importance of explaining what the jury may, and may not, consider when deliberating. 

What you'll learn:

  • Why you should explain in detail what jurors should not consider when considering their verdict.  
  • How to empower a jury to reach a verdict without regard to outside considerations. 
  • Building credibility with jurors by addressing concerns. 

Quotable moment:

 The fact that you’re opening up with the jury and you’re telling them about your fears of stuff, it gives them a connection with you, also, that helps establish why you’re the most credible person in the room. Goldberg on explicitly addressing potential concerns jurors might have concerning their verdict. 

Telling your client's damages story

Brad Thomas uses video from his closing in a TBI trial to lead a discussion on the most effective ways to detail the impact your client's injury has had on their life. 

What you'll learn:

  • How to pick the best moments from your client's life in showing the impact of an injury. 
  • Why incorporating your own experience into your closing makes your argument more effective. 
  • When to use a script or PowerPoint during closings... and when to put it away. 

Quotable moment: 

If you spend time with your clients and the pain and suffering witnesses, it becomes effortless to tell the story about how this has impacted them.  — Thomas on how to find the most powerful moments in telling your client's damages story.   

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Violations of the rules by defendants

With video from a trial involving the catastrophic brain injury a woman suffered in a fall from a municipal paratransit bus, Goldberg leads the discussion on how to highlight a defendant's rule violations.

What you'll learn:

  • How to build a powerful argument of a rules violation. 
  • The best sources of evidence to support your rules violation argument. 
  • Different approaches to preparing the most effective closing argument. 

Quotable moment:

I always say experts are your last resort that you have to go to if you can’t find (evidence supporting rules violations claims) anywhere else.Goldberg discussing the most valuable sources for presenting a rules violation argument. 

Calculating damages for pain and suffering

Eric Rogers uses video from his closing in a motorcycle crash trial to lead the discussion on powerful techniques for breaking down a damages claim. 

What you'll learn:

  • How to deliver a resonant damages argument. 
  • The best ways to break down the damages number for a jury.
  • Determining the best amount to request.
  • Alternatives when a jurisdiction doesn't permit requesting a specific figure for non-economic damages.

Quotable moment:

When you’re asking for a number like $10 million you can’t make it about a few years of time. It's got to be something life altering, and the bigger you make it, the easier it is for a jury to understand it and to award it. Rogers on the importance of powerfully emphasizing the magnitude of the impact relative to the damage award. 

Using jury charges to focus the jury

With video from trial over a patient's fall from a hospital wheelchair, Goldberg leads a discussion on how jury charges can be an important tool in closings.  

What you'll learn: 

  • Why finding the best jury charge to emphasize may be critical to your case.
  • How to best walk jurors through jury charges. 
  • Selecting and arguing for the appropriate jury charges for the circumstances of your case.

Quotable moment:

You’ve got to make sure you’re getting the charge, and then once you’ve got it, you’ve got to make sure you’re explaining it to the jury and not just glossing over it.— Goldberg on selecting and properly explaining the jury charges that bolster a case.  

Closing rebuttal

Using video of his argument that won a  $25 million verdict for a paratransit bus passenger's fall, Fried leads a discussion on the keys to closing rebuttal.  

What you'll learn:

  • How to best balance planning for rebuttal while remaining flexible for last-minute changes.
  • How your rebuttal may be "stolen" and how to potentially prevent it. 
  • Why rebutting every defense point may be a mistake. 
  • How to flip defense arguments to your advantage in rebuttal.

Quotable moment:

 “Pick some things that, as you're rebutting them, what you're really doing is showing that [the opposing counsel is] being gamey, that they're being unfair, that they don't deserve the credibility in the case. — Fried on opposing counsel arguments that should be incorporated into closing rebuttal. 

Next Steps

CVN offers hours of video on the topics the Fried Goldberg attorneys discuss. Here's where to head next in our library. 

Watch CVN's trials featuring Fried Goldberg attorneys

Learn about the 10 must-watch TBI trials in CVN's library.