Preparation, preparation, preparation of your case should be your mantra and motivator to building your trial strategy.
Once you know how you will be presenting your case you then build your witnesses to support the evidence. You must determine want you want out of your witnesses before you begin preparing them.
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.”
By using this approach you will be able to build the four corners of their testimony. This “Box Of Knowledge” is designed to keep the witness aware of their actual knowledge and avoid making statements of opinions, assumptions, speculations and conjectures.

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