Preparing witnesses : a practical guide for lawyers and their clients

This completely revised and updated Fourth edition will improve your witness preparation skills. This new edition includes a new focus on the gaps perceived between the attorney and witnesses, and how to effectively bridge those gaps. New chapters study special situations, and how to deal effectively with those situations. The book also includes a CD-ROM with all the accompanying appendix material, including memoranda outlining the rules of witness preparation.

"Please raise your right hand" -- Why tell the truth? -- The gaps -- The perception gap -- The audience gap -- The conversation gap -- The control gap -- Preparing ourselves -- Understanding the audience -- Three mistakes witnesses make -- Seven mistakes lawyers make -- What preparation means -- Basic principles -- Rule 1: "Take your time" -- Rule 2: "Always remember you are making a record" -- Rule 3: "Tell the truth" -- Rule 4: "Be relentlessly polite" -- Rule 5: "Don't answer a question you don't understand!" -- Rule 6: "If you don't remember, say so" -- Rule 7: "Don't guess" -- Rule 8: "Do not volunteer" -- Rule 9: "Be careful with documents and prior statements" -- Rule 10: "Use your counsel" -- Making an impact -- Adapting to the situation -- The deposition witness -- The grand jury witness -- The trial witness -- The party witness -- The expert witness -- Corporate representative witness -- The physician as witness -- The criminal defendant -- The ethics of witness preparation -- The witness bill of rights -- Conclusion.