With Witnesses, Focus on the Big Picture First

We’ve found that when prepping a witness for trial or deposition, many attorneys jump right into the medical records, corporate documents, employment files or other minutiae.

It’s understandable, because these are the documents you use to build your case – but we believe it’s misguided.  We believe it’s first necessary to focus on the big-picture themes that form the bedrock of your case, and only delve into the details when the witness has internalized the bigger ideas.

From our perspective, the first and most important goal of a prep session should be to formulate the witness’ message safeground – an idea (or two or three) that encapsulates the witness’ message to the jury and serves as a lens through which the witness can view the details.  Keeping the message safeground in mind allows the witness to see how the details fit into the bigger theme of the case.

What the message safeground is not is a rote statement for the witness to repeat ad nauseum.  Instead, a witness should keep the message safeground in the back of his or her mind and consider how each detail to be covered during testimony relates to that theme.  This results in testimony that is both consistent and supports your broader theme of the case.

We’ve prepped hundreds of witnesses of all types through the years, and the message safeground is just one aspect of the successful process we’ve developed.  If you have a witness that could use our help, contact Senior Vice President Claire Luna at cluna@juryimpact.net or 714.754.1010.