75. Prep for Success: Controlling Your Witness through Thorough Preparation, with Tom Innes and Mary DeFusco

According to Philadelphia trial lawyers Tom Innes and Mary DeFusco, preparing your witness for testimony is a bit like training a guide dog: the real work happens long before the leash comes off. In this episode, Tom and Mary talk about how to create control in ever-important prep sessions prior to testimony—and they share hands-on, practical tips that will help your witness give their testimony while staying cool and collected, on track, and under control.  Topics4:04  Why preparation is the first step5:38  Deposing Dr. King on The Pitt8:11  Your witness’s role  10:30  Organization of testimony, explained11:50  Under pressure13:50  Cross prep15:33  Practice pointers19:13  Ethical considerations23:02  Signoff questionsQuotes“Practice having the witness speak to the jury both on direct and cross. Speak to the jury—even if all you can do is set up some empty chairs as a jury box.” Tom Innes“It’s a really bad look in front of a jury when the witness answers every question promptly on direct but then very slowly on cross.” Mary DeFuscoResourcesTom Innes (bio)Mary DeFusco (bio)Judge L. Felipe Restrepo (bio)Building Trial Skills: Philadelphia (program)Cross-Examination Math (podcast episode)