Trial attorneys have at most four opportunities to speak to a jury: 1) a brief opening statement prior to jury selection (state only and on request); 2) jury selection, or “voir dire” (“to see one say”); 3) opening statement; and 4) closing argument. The first two are before the jury is selected, and only in the second, jury selection, is one permitted to ask potential jurors questions and hear their answers. This golden opportunity should not be squandered through ill preparation.
In federal civil practice the judge retains tight control over voir dire and need not allow attorneys to ask questions. read more