Trial Consultant & Mediator in Santa Monica, CA providing trial strategy, witness preparation and litigation support...Read More
You need to determine what testimony you expect from your witnesses’ depositions and trial testimony before they get deposed. I use a technique that builds the parameters and boundaries of the witness’s actual knowledge of the facts that pertain to the case. This technique builds their “Box Of Knowledge.”
How do you avoid telegraphing? Embrace your facts and take the emotions out of those bad or problematic facts. If you are comfortable with the issues and weaknesses of your case then the message to the jury is “it’s not a problem, just a fact.” Don’t build the facts against your own case let your opponent do their own work.