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Author Archives: Daniel Small, BridgeTower Media Newswires

Be careful with documents, prior statements

The witness is just settling into the deposition, starting to sense that there may be light at the end of the tunnel, when the questioner pulls out the first document. She waves it around with great flair, asks a few “isn’t-it-true” type questions and slaps it down on the table.

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Making an impact on a witness

In past columns, I’ve talked about the “10 Rules” for witnesses as a way to help bridge the wide gap between normal conversation and communicating in a witness environment. The first is easy and natural; the second is difficult and unnatural — and treacherous. The language, rhythm and goals of each are very different.

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What it means to prepare a witness

Too many lawyers — including some very good ones — don’t prepare witnesses adequately because they fail to understand that being a witness is dramatically different than anything else the client has experienced.

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