Witness Preparation from Another Perspective
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The importance of witness preparation applies whether you are the Defendant in the litigation or the Plaintiff. Here is a link to a good article on witness preparation from the perspective of the Plaintiff. www.tlrcblog.com/2007/06/articles/-case-work-up/tips-on-defending-personal-injury-depositions/ In his post, Tips on Defending Personal Injury Deposition, Ron Miller provides 6 tips on how to prepare a Plaintiff for his deposition. From my experience, his advice for Plaintiffs is right on target. When I take a Plaintiff's deposition, the main piece of information I am looking for is what type of impression this individual will have on a jury. To me, this is even more important than what the Plaintiff says about the accident or his injuries. As a defense lawyer, I can always deal with his testimony regarding the facts. What can be much more difficult to deal with is how he will present as a witness. A Plaintiff that makes a good witness in his deposition will enhance the value of his case and make it more likely to settle. The converse is also true. A Plaintiff who makes a poor witness will decrease the chances that his case will settle. Fortunately, for me, most lawyers do not spend much time preparing their clients to be good witnesses. This is a universal problem on both sides of the docket.
