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Preparing Witnesses to Give Effective Testimony: The Attorney's Essential Guide



A must-read guide for trial attorneys who prepare witnesses for deposition and trial. The pointers are practical and effective, and they will improve even the most challenging witness. Chapters focus on the importance of preparation, setting and achieving individualized objectives, witness assessment techniques, managing expectations, steps in conducting an effective preparation, matters of memory and recall, dealing with special issues and other chapters. The authors are experienced litigation psychologists who have prepared thousands of witnesses. The book includes many examples and helpful lists. A handbook for witnesses is also available as a companion to this book for attorneys. Should be read by every trial attorney, whether newly admitted to the bar or seasoned. Also available in Kindle™ and Nook™ versions.




The evidence in a case usually speaks for itself, but how well will your witnesses speak for the facts? How convincing and believable will they be? How truthful will they appear to the triers of fact? How effective? How influential and persuasive? How will they impress jurors? How can an attorney get maximum value from the time he or she will spend preparing witnesses to give effective and credible testimony?


The ability to prepare witnesses effectively is perhaps the most important and frequently used skill a trial attorney can possess. This book develops skills in both assessing and addressing the communication needs of individual witnesses. The information, examples, and tips are provided by consultants with several decades of trial consulting experience preparing several thousand witnesses.


See also the companion publication for witnesses, The Better Witness Handbook.



Chapters in the book cover such important topics as:

  • Why witness preparation is critical to your case
  • The perspective from the witness chair
  • Setting and achieving witness preparation goals
  • Witness assessment
  • Managing expectations for your witnesses
  • What your witness really needs to know
  • Steps in conducting an effective preparation session
  • Matters of memory and recall
  • Special witness preparation challenges
  • Dealing with emotional needs



“This book’s pointers are practical and effective, and they will improve the testimony of even the most challenging witness. As I read it, I found myself scribbling notes on my next witness preparation outline. I hope opposing counsel never finds this book.” 


“This book by consultants with years of hands-on experience empowers the trial team to guide the client on how to testify their truth in a personable, confident, and convincing manner while avoiding pitfalls from opposing counsel. The information is presented in an engaging and useful way.”


“The authors are especially effective in distinguishing between what witnesses need for deposition versus trials. This book can serve as a thoughtful, how-to-do-it resource for attorneys who seek to spend their time well in the preparation of credible witnesses.”

Preparing Witnesses to Give Effective Testimony

SKU: 978-0977751167
$24.95 Regular Price
$19.96Sale Price

Angela M. Dodge, Ph.D.

Angela Dodge Ph.D. is the owner of Dodge Publications, which produces and distributes various publications in the legal field. An experienced trial consultant and social psychologist, she has assisted attorneys across the country with witness preparation, juror-sensitive trial strategy, jury selection, and pre-trial research (focus groups and mock trials). She has prepared several thousand witnesses for depositions and trial, using simulation methods, practice question-answer segments, demeanor and dress coaching, and team feedback techniques. Her methods were developed from working on a variety of legal cases, a range of witness profiles, and information gained through post-verdict interviews with actual jurors in many venues. Her expertise in the areas of courtroom communications and jury persuasion has also helped attorneys formulate winning trial strategies and effective jury de-selection techniques throughout the country and particularly in the Pacific Northwest.


Incorporating her knowledge and experience gained through 25 years of working on several thousand legal cases, Dr. Dodge has authored and/or co-authored a number of guidebooks for attorneys, law professors, law students, healthcare professionals, and other trial advocates. She built a solid reputation as a consultant and seminar speaker, and she has addressed many state, regional and national law associations. Her current focus is on the marketing and distribution of the firm’s publications.



John H. Ryan, Ph.D.

John Ryan Ph.D. is a litigation psychologist based in the Seattle/Tacoma area of Washington State. Dr. Ryan has worked on several hundred civil lawsuits, consulting with attorneys on witness preparation for deposition and trial, conducting pre-trial focus groups and mock trials, and assisting with juror assessment and jury de-selection by preparing juror questionnaires and voir dire examination questions. He has conducted several hundred legal focus groups and applied results to the development of effective trial strategy and witness preparation techniques. Litigation stress management for physicians and other professionals has also been an important element of his practice.


Much of Dr. Ryan’s trial consulting work has focused on professional negligence defense and a variety of civil lawsuits involving personal injury, school and workplace discrimination, wrongful death, police action, and sex abuse. In addition to Preparing Witnesses to Give Effective Testimony, he is the co-author of The Better Witness Handbook, a guide for witnesses required to give testimony in all types of litigation. He has special expertise in working with highly anxious and antagonistic witnesses.

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