Lawyers’s Preparation For The Examination In Chief

 (A) Planning Ahead: What is the Witness’ Role?

1. The Theme of the Case.

2. The Order of Witnesses

3. What witness says

(B) Preparing the Witness. 

1. Prior Testimony.

2. Current Testimony.

3. The Use of Documents to Refresh Recollection.

4. The Cross-Examination Drill.

5. The Rules of Evidence and the Need for Objections

(C) The Direct Examination:

1. Organizing the Direct.

2. The Form of the Question.

3. The Use of Non-Verbal Evidence.

4. To overcome with the mistakes that the witnesses have made.