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Question: "How old is your son, the one living with you?" Answer: "Thirty-eight.” Question: "How long has he lived with you?" Answer: "Forty-five years.” Is this your client? Do you struggle to try keeping your witness from looking like a deer caught in headlights?...

You drilled your client not to volunteer any information not asked for by opposing council, and yet, here he is, offering up details to the other attorney in deposition who’s politely egging him on. You’re muttering to yourself, “We discussed in the witness prep...

When your client answers opposing council’s questions, it’s a lot like a baseball player going to bat. The batter has to read the pitch and detect if the pitcher is throwing a curveball, fastball, splitter, or change up. An attorney can trip up your client much like a...

Preparing a witness for a deposition is like teaching them a new language. They need to study the vocabulary and how to construct sentences, rules of grammar and eventually be able to speak fluently in that new tongue. Your clients are learning a new language when you...

If your client doesn’t appear in front of a judge, jury, or video camera as believable, genuine, and authentic … they’re toast. As you know, your client's credibility is everything and it can vanish in a heartbeat if your client won’t stop talking at their deposition...