SKU: DEP4006 Categories: ,

Deposition & Trial Testimony – Witness Preparation Instructions: (“Pointers for Witnesses”)

“Prepare your witnesses to testify effectively! Give your witnesses take-home testimony instructions that they can review several times.”

You’ll give this skill builder to your client and witnesses, before a deposition or trial, to improve their ability to testify effectively. Have them take it home to reinforce your office-delivered message of what the witness must do to avoid the traps of the adversary lawyer.

$29.00 – Delivered electronically – now – in PDF, as part of the purchase process.

Four pages of tips for the lawyer, plus four pages of take-home form for your witness, does this for you:

  • Witness Instruction Handout gives you a format for your first office talk to witnesses about the techniques of testifying.
  • Witness Instruction Handout can be taken home and reviewed by the witness every day before the deposition or trial.
  • Witness Instruction Handout is a great teaching tool. It drives home your message of what the witness must do to avoid the traps of the adversary lawyer.
  • Witness Instruction Handout tells the witness how to be an effective witness conveying facts to the jury.
  • Witness Instruction Handout is in language that you want the jury to see if the witness says he got materials from you.

This form (#4006) deliberately excludes the information your witness will want to know if the deposition is to be video-recorded (by you or the adverse party). It is contra-productive to give a witness information which appears useless to them, mixed with information they do need. Therefore, we have a separate “Witness Instruction Handout” (#4008) to prepare witnesses for video deposition. The video deposition handout form #4008 contains much of the same material as the form discussed on this page — but adds the material relevant and important to training for a video-recorded deposition. Many law offices have both this form (#4006) and the video deposition form (#4008) available, to hand out the most appropriate form to their witness.

If you want a similar camera-wise set of Pointers for Witnesses that is written specially for your expert witnesses, take at look at our Expert Witness Pointers for Video Depositions.

We do not provide a DVD type of handout for witnesses. Our experience is that prospective witnesses report watching a video once or twice, but they read and reread the written advice several times. We are not sure why it seems true, except possibly it takes less time to read then to watch a DVD illustrating the points. If you want a DVD type of advice to witnesses, several bar associations do have them for sale, as well as some commercial producers (but with a copyright restriction prohibiting you from giving each witness a copy you made yourself). All in all, we think the written advice is not only less expensive for most attorneys to use for all witnesses, but also is more effective. That’s why we designed and sell our Witness Pointer series.

Most witnesses have never testified in a deposition or in a trial. When they get to the deposition or trial, they mumble, hesitate, and drop the ball. They are fearful of what every moment will bring. At a trial, they exhibit the signs of fear that the jury thinks are signs of weakness of memory, or worse, of lying. At a deposition they exhibit the signs of fear that the adverse attorney exploits to downgrade the settlement value of the case. Why are most witnesses like that?

The attorney has not prepared the witness.

You do not want to be one of those lawyers! You know that you have to spend time with the witness in your office. You also know that you need a Witness Testimony Instruction Handout. Why not get the best!

If Witness Testimony Instruction Handout saves you just one case from collapsing – ever – it will have paid for itself many times over.

All top trial attorneys I know say a witness testimony instruction handout is a necessity. You cannot expect a client or witness to remember a half hour (or more) of “how to testify” tips given to them by you in the office unless they have something to review several times at home.

The LawyerTrialForms™ Witness Instruction Handout(it’s also called “Pointers for Witnesses”) is the best witness testimony instruction form I’ve seen — a real value for the instruction it gives your witness.

For example, I’ve never seen any other witness handout that uses a tip given to national television speakers on how to sit. Witness Instruction Handout tells your witness the “Power Position” way to sit that instantly gives them relaxation while conveying a positive message of power and confidence. And that is just in the opening few paragraphs of this teaching tool.

Be one of the few attorneys who effectively prepare their witnesses.

All The Best,
Leonard H. Bucklin
Leonard Bucklin, Civil Trial Attorney


SKU: DEP4006 Categories: ,