Trial Counsel for Law Firms

Preparing Your Client to Testify

What do you do to prepare your client to testify?

When an examination, trial or hearing is imminent, there’s usually a long to do list and limited time.

Preparing the client to testify sometimes takes a backseat to other priorities. And it shows. The underprepared client is vulnerable.

Here are some recommendations to help get your client ready to testify:


Provide the client with our memo to witness about to testify, including:

  • Tips on testifying;
  • Documents to review; and
  • Issues they are likely to be asked about.

For out of Court examinations, provide a copy of our mock transcript.


Meet with the client to discuss the case, what to expect, key documents and key issues.  They’ve probably got a good sense of things and this meeting is a helpful review and opportunity to go over the finer details.


Meet with the client to rehearse (not memorize) direct examination and practice cross-examination.  You need to rehearse direct examination because of the nature of open-ended questions.  Otherwise you may not get the evidence you want in response to open-ended questions.

The gold standard is that the lawyer actually prepares a cross-examination and cross-examines their own client.  This is quite a bit of work, but worthwhile if you want to ensure the client stands up well to cross-examination.

Court Agent

We offer a number of Court agent services to law firms. In terms of preparing your witness to testify, we can assist in helping the client to appreciate what to expect, drafting an outline for direct examination and our most valuable contribution is preparing and performing a practice cross-examination.

Hassell Trial Counsel
111 Greensides Ave
Toronto, Ontario M6G 3P8

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