How to Get a Witness to Start with the Basis for Opinion

lawyer asking judge to voir dire adverse witness on basis for her opinionCan the adverse party require that a witness on direct examination testify to the basis of his or her opinion before stating that opinion? Short answer, no. But there still may be a way to do it. Continue reading

Do You Know When to Use a Subpoena?

A “subpoena” is a writ or an order that compels a witness to either show up and testify or produce something. CCP §1985(a). You can use a subpoena in discovery or in a civil trial or hearing. Here’s a look at which type of subpoena to use in common situations. Continue reading

Make a Plan for Each Witness

85449216Before you prepare a witness for trial, you should know precisely what you expect to accomplish through that witness. In other words, have a plan. Continue reading

Are Two (or More) Experts Better Than One?

sb10063567v-001Should you hire multiple experts on the same topic? There are some very good reasons to use this strategy. Continue reading

5 Steps to Fixing the Facts in Your Client’s Mind

176421487If properly prepared, your testifying client will be relaxed, confident, natural—and a master of pertinent facts. But no one can behave naturally on the stand while trying to keep in mind 50 different facts. When you’re preparing your client to testify, your job is to narrow the case to a few important facts and then fix them in your client’s mind. Continue reading