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The Better Witness Handbook: A Guide for Testifying at a Deposition, Hearing, or Trial



Every day people give testimony under oath without knowing the legal rules or having some practice in how to listen and respond effectively to questions they will be asked by attorneys or judges. This handbook is written to help the inexperienced person better prepare to give testimony. It also answers many basic questions, such as what the difference is between a deposition and trial testimony, why a deposition is taken and who will be attending, what kinds of questions will be asked and how to formulate effective answers, what to do if one's memory fails, how to get through a difficult cross-examination, how to avoid clever lawyer traps or attempts to put words in one's mouth, the best ways to control anxiety and worry, how to dress to make a good impression, and what demeanor is appropriate or inappropriate for the deposition and courtroom. The reader learns what to expect so that he or she will be better prepared to face any questioner with confidence and a realistic understanding of what will happen at a deposition, hearing or trial, and why. In short, the reader will be a better, more effective truth-teller. The book includes many examples demonstrating the principles and guidance that apply in a variety of situations. Also available in Kindle™ and Nook™ versions.



Every day, people give testimony at hearings, depositions, and trials without knowing the legal rules or having some practice on how to listen and respond effectively to questions they will be asked. Despite television portrayals, giving testimony under oath is not the same as having a conversation. In reality, it is unlike any form of communication most witnesses have had. Basic familiarity with the legal process and an opportunity to practice various question-answer formats enables a witness to enter the legal arena with less anxiety and more confidence.



People with little or no experience as a witness have many valid concerns and questions. This book build witness confidence and effectiveness by providing practical advice on such topics as :

  • The difference between a deposition and trial testimony
  • Why a deposition is taken and who will attend
  • What kinds of questions will be asked
  • How to answer questions effectively and with confidence
  • Avoiding clever attorney traps and attempts to put words in one’s mouth
  • What to do if memory fails or recall is impossible
  • How to get through a difficult cross-examination
  • Best ways to control anxiety and worry
  • How to dress and act to make a good impression
  • How to act at a deposition and at trial
  • Becoming an overall better communicator


After reading this book, a witness will know what to expect and be well-prepared to face any questioner with confidence. In short, it helps convert inexperienced witnesses into better witnesses!

The Better Witness Handbook

SKU: 978-0977751198

John H. Ryan, Ph.D.

Dr. Ryan is the president and managing partner with Dodge Consulting & Publications, LLP. An experienced consultant and clinical psychologist, Dr. Ryan has 35 years of experience in communications, group dynamics, stress management, and mediation. As an expert in interpersonal dynamics and human behavior, he provides a variety of litigation consulting services, including witness preparation, jury selection, and pre-trial focus groups.


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.


John H. Ryan, Ph.D.

John Ryan Ph.D. is the 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.