WITNESS PREPARATION
Case 2: Mr. D.P.

In a prior case, Mr. D.P. was being deposed. His lawyer had only briefly prepared him because he was just a fact witness for a colleague. Forty-five minutes into the deposition, the attorneys stepped out.

Opposing counsel returned and announced that the deposition was now over because Mr. D.P. had just become a co-defendant. Mr. D.P. was shocked, overwhelmed and scared.

Several years later, Mr. D.P. became the defendant in another lawsuit. His attorney brought us in to prepare Mr. D.P. He didn't think it would do any good, but his client was so nervous, he had to try something.

ON TRIAL spent one day going over testimony and key issues and developing positive ways for Mr. D.P. to respond. Then we began preparing him for the emotional aspects of his deposition: his fear of attorneys, his anxiety about his own competence in public speaking, his anger at his former attorney, his reluctance to say anything at all, and his bitterness about the legal process. We videotaped a mock examination and went over precisely what would happen at the deposition. We gave Mr. D.P. the experience of being believed.

Mr. D.P. changed entirely. His performance at the deposition was stellar. He was clear, calm, and positive.

In the past, his attorney had used a "psychologist-type" witness coach but it hadn't worked. After seeing the results of our coaching, the attorney declared he was a "convert" and would never go to another deposition without us.

REVIEW CASE 3