Preparing witnesses : a practical guide for lawyers and their clients / Daniel I. Small.

Includes bibliographical references and index.

"Please raise your right hand" -- Why tell the truth? -- The gaps -- The perception gap -- The audience gap -- The conversation gap -- The control gap -- Preparing ourselves -- Understanding the audience -- Three mistakes witnesses make -- Seven mistakes lawyers make -- What preparation means -- Basic principles -- Rule 1: "Take your time" -- Rule 2: "Always remember you are making a record" -- Rule 3: "Tell the truth" -- Rule 4: "Be relentlessly polite" -- Rule 5: "Don't answer a question you don't understand!" -- Rule 6: "If you don't remember, say so" -- Rule 7: "Don't guess" -- Rule 8: "Do not volunteer" -- Rule 9: "Be careful with documents and prior statements" -- Rule 10: "Use your counsel" -- Making an impact -- Adapting to the situation -- The deposition witness -- Grand jury witness -- The trial witness -- The party witness -- The expert witness -- Corporate representative witness -- The physician as witness -- The criminal defendant -- The ethics of witness preparation -- The witness bill of rights -- Conclusion.