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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.” - PETER B. MOORES, Partner Choate, Hall & Stewart LLP Boston, MA


“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.” - ERIC HOLM, Vice President of Claims, Physicians Insurance Company, Seattle, WA


“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.” - STANLEY L. BRODSKY, PHD, Professor, Department of Psychology, The University of Alabama, Author of The Expert Expert Witness and other books on witness preparation

Preparing Witnesses to Give Effective Testimony

SKU: 978-0977751167

John H. Ryan, Ph.D.

John Ryan Ph.D. is the president and managing partner with Dodge Consulting & Publications, LLP, a litigation consulting firm in the Seattle/Tacoma area of Washington State. An experienced litigation psychologist, John 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 nearly 100 legal focus groups and applied results to the development of effective trial strategy. Litigation stress management for physicians and other professionals has also been an important element of his practice, including individual therapy and life skills coaching.

Much of John’s trial consulting work has focused on medical malpractice defense and a variety of personal injury, school and workplace discrimination, wrongful death, and sex abuse civil lawsuits. He is co-author of the attorney guidebook, Preparing Witnesses to Give Effective Testimony, and 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. Dr. Ryan’s related prior experience includes maintaining a clinical psychology practice for over 25 years, consulting on state and federal projects for individuals with disabilities, coordinating community development projects, and providing market research consultation services. John earned his Master’s Degree in Counseling (1977) from Troy State University in Alabama, and his doctorate in Professional Scientific Psychology (Combined Clinical and Counseling) in 1983 from Utah State University. He is also a graduate of the US Air Force Academy (1969) and served honorably as a pilot in the USAF.



Angela M. Dodge, Ph.D.

Angela Dodge Ph.D. is the Founding Partner at Dodge Consulting & Publications LLP, a litigation consulting firm in the Seattle-Tacoma area of Washington State. An experienced trial consultant and social psychologist, she has helped hundreds of attorneys across the country with witness preparation, juror sensitive trial strategy, jury selection, and pre-trial research (focus groups and mock trials). Her expertise in the areas of courtroom communications and jury persuasion has helped attorneys formulate winning trial strategies and effective jury de-selection techniques throughout the country and particularly in the Pacific Northwest.

Angela has special expertise in working on medical/dental malpractice defense cases, and has prepared several thousand doctors, nurses, and other healthcare professionals to give more effective and compelling testimony. She has conducted hundreds of pre-trial focus groups to assess case strengths and weaknesses, and many post-verdict interviews to determine how and why juries arrive at their verdicts. Although she is particularly experienced in de-selecting high risk jurors in medical malpractice trials, she has also consulted on a wide range of civil lawsuits, including personal injury, wrongful death, child/sex abuse, insurance coverage, employment issues, product liability, civil rights, and business fraud.

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 has a solid reputation as a consultant and seminar speaker, and she has addressed such groups as the Ninth Circuit Chief District Judges, Washington State Bar, Montana Defense Trial Lawyers, Oregon Law Institute, Defense Research Institute, Birth Injury & The Law Annual Conference, Washington Defense Trial Lawyers, Physician Insurers Association of America, and numerous other county and local organizations. Her current focus is on the marketing and distribution of the firm’s publications.

Angela earned her undergraduate degree summa cum laude at the University of North Dakota (1972) and her doctorate at the University of South Carolina (1976). Prior to her career as a litigation psychologist, Dr. Dodge worked in the areas of education research, manpower development, and organization development consulting.