Dr. Noelle Nelson

Book: 101 Winning Tips: How to Give a Good Deposition & Testify Well in Court
101 Winning Tips: How to Give a Good Deposition & Testify Well in Court
101 Winning Tips: How to Give a Good Deposition & Testify Well in Court

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Giving a deposition or testifying at a trial can be a painful and costly experience if you aren’t well prepared! Use these 101 easy tips as a jump-start to successfully prepare for your turn on the stand or in deposition.

The tips are the result of Dr. Noelle Nelson's working as a trial consultant with lawyers and their witnesses for over 25 years. You can see more about her work in the “client results” section (trial consulting tab) of her website: www.noellenelson.com.

Unless specified otherwise, all the tips are equally valid for both deposition and trial.


Here’s what some lawyers have said about Dr. Nelson’s witness preparation techniques:

"Noelle Nelson is an excellent jury consultant. We used her in a … case to work with some particularly troublesome defense witnesses. She did a fine job coaching these witnesses on how to make a gentler, kinder, less defensive presentation in their testimony to the jury. She is easy to work with and quickly gains the cooperation and respect of even the most cantankerous witness. It is clear that she has mastered the techniques of teaching people how to make verbal and non-verbal responses which maximize their impact on the listener."

- John B. Golper, Attorney; Ballard, Rosenberg & Golper

"If your case is burdened with the witness from Hell, don't despair, try the magic of Dr. Noelle Nelson's advice. I have seen her witness preparation skills turn a frog into a prince."

- Howard A. Jaffe, Vice Chairman, COO & General Counsel, The InterGroup Corporation

“Dr. Nelson’s brilliance is evident in both her revealing insights into the courtroom drama, and her ability to effectively translate those insights into workable ideas for greater success. . .”

- Marcia G. Lamm, Ph.D., Director, West Valley Psychological Clinic

Tips are divided into 10 topics:

  • Attitude
  • Appearance
  • Stop, Listen, Think
  • Typical Questions
  • Tricky Questions
  • Clarity
  • Deposition Specifics
  • Trial: Direct Examination
  • Trial: Cross Examination
  • Final Words

Sample Tips:

Keep your body language open and undefended. Don’t cross one or both of your arms over your chest, it’s read as defensiveness. Avoid slumping, slouching, twisting your body to one side, leaning to either side, or supporting your chin with your hand, elbow on the table.

Be consistent. If you’re asked the same question in slightly different ways, stick with your original answer. Only change it if it’s inaccurate, not just because opposing counsel repeats the question.

Give the information requested, not more. Don’t volunteer. If you’re asked for one example, give one, not two. If you’re asked for your date of birth, don’t volunteer where you were born and how happy your Mom was.

Answering the document question: “Isn’t it true that you signed the May 3rd agreement?” “May I see the document please?” Always review whatever document is being referred to before answering, even if you think you know what it is.

Withstand personality influence. Opposing counsel may act like your best buddy - casual, easy-going, warm-hearted, friendly and nice. Don’t be swayed. It’s the “honey attracts better than vinegar” approach, and you’re still the fly.

Be wary of the “yes” set. Opposing counsel wants to get you to agree to their version of the facts. When you find yourself agreeing with opposing counsel – as sometimes you must (“The earth is round, isn’t it?”), listen extra carefully to the next questions. The more times you say “yes” the more likely it is you’ll say “yes” when you shouldn’t.

Deal with inconsistencies appropriately. You will inevitably say something on the stand that is different from what you stated at deposition. Opposing counsel will pounce on it. “At your deposition, you said you didn’t see the specs, but now you tell us you did. Were you lying then or now?” Stay calm. “I’ve had more time to think about it, and I realized I did see the specs.” Your unruffled response will tell the jurors it’s no big deal.

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