Preparing Witnesses to Give Effective Testimony

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.”

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.”

Professor, Department of Psychology, The University of Alabama
Author of The Expert Expert Witness and other books on witness preparation


Price: $24.95
ISBN: 978-0977751167
PAGES: 117
SIZE: 6" x 9"
EDITION: First (2013)


Angela M. Dodge, Ph.D.

Angela M. Dodge is a litigation psychologist whose consulting practice is based in the Seattle-Tacoma area of Washington State. She has prepared several thousand witnesses to give more effective and compelling testimony. Her expertise in assisting with jury selection, conducting pre-trial focus groups, and in preparing witnesses for deposition and trial has earned her a solid reputation as a consultant and conference speaker. In addition to her practice, she is currently lead author on a series of handbooks on specific jury-focused strategies for contemporary trial practice.

John H. Ryan, Ph.D.

Dr. Ryan is a senior 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.