Witness preparation—in general

Witness preparation—in general

Each defense witness should be thoroughly interviewed concerning all matters he or she is to testify to in court. Counsel, of course, will make the ultimate decision whether to call the witness. Defense counsel should not be influenced by the insistence of the client that a certain witness be called. The criteria include ability to recall, ability to relate to people, intelligence, prejudices and biases, appearance, personality, and general affability.FN73 Every important witness should be thoroughly grilled as preparation for a possibly-damaging cross-examination. A mock examination and cross-examination should take place between the attorney and important witnesses before the trial.FN74