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Witness Preparation

Not every client is a perfect witness. In fact, not every witness can be perfect witness. One witness might not be able to win a case for you, but they could accidentally lose it for you.

Testimony in a courtroom can be terrifying and even traumatic for your witnesses, and they can range from shy and hesitant to utterly problematic. And not every lawyer has the time to sit down with each witness multiple times and figure out the best way to help them communicate their story.

Luckily for you, Elizabeth has a personal passion to help witnesses prepare fulfill their role in their own case by testifying.


"Our case involved a client with previous negative experiences with lawsuits and depositions. Elizabeth took extra time to help on this particular concern and empowered the client to make his deposition a positive experience – one that allowed him to be confident. Client gave a great deposition, and the help Elizabeth gave also improved our relationship going forward with the client."

~ Steve Samples & James Ames | Samples Ames pllc
Fort Worth, Texas

5 Common Mistakes Lawyers Make
in Client Witness Preparation
(and ways to fix it):

How witness preparation works

Communication is challenging. We all struggle to communicate clearly and effectively in a world full of texts, emails, and videos.

Now add lawyers, a judge, jury, and cross examination questions. It’s no wonder clients and witnesses are terrified to take the stand. Sadly, some clients would rather settle their case instead of go to trial because of their fear of taking the witness stand. There is a tremendous amount of fear and pressure around testifying.

Witness preparation is not new, this is a problem lawyers have long had to solve in this profession. But not all preparation is created equal.  Telling a client or witness to just “tell the truth” is obvious, its like telling a five year-old learning to tie their shoes “use the laces.” People know its about telling the truth, and they want more then a list of rules or what not to do.

Preparation of a client or witness should incorporate both emotional and logical components. It’s more than just role play.

Generally, lawyers do tackle the logical components: what to say and running through some sample questions. Unfortunately, I have seen lawyers skip the difficult facts or strong defense claims because its uncomfortable.

Also it’s the emotional components that can become obstacles in preparation and testimony. For example, deep emotional injuries take time, trust, and patience before they emerge from a client or witness. Some times you don’t know how to tackle the emotional parts or the client won’t open up despite your efforts.

Clients and their stories are unique. Their preparation should be handled the same way.

Elizabeth customizes this process for each individual’s client based on their needs and situation. This process takes place over 2-3 days and Zoom meetings to assist the client with confidence against cross examination, content creation and telling their unique story.  Elizabeth works with you (the lawyer) throughout the process, as well, and provides direct guidance on best ways to communicate. She can and will use focus groups to help understand the jury’s blink reactions and perceptions of a witness.  Her consultation will cover all your concerns and ensure that all the witness preparation aligns with your plans for the case.


Why would I need a lawyer to do something I can do?

Bringing in an outside lawyer can give a fresh perspective on problems that may be impeding testimony, offer new tools or tips for preparation or free up time.

Will Elizabeth assist me in writing direct examination questions for trial?

Yes. She can help craft questions best suited for the client.

Will Elizabeth present the client at their deposition?

Not typically. Elizabeth is happy to discuss with the lawyer.

Will you travel / come to me?

Yes, as part of Larrick Law Firm consulting services, I can travel to you.

Deposition Preparation

When preparing your witness for a deposition, you need to make sure your witness not only understands the purpose of a deposition, but also the purpose of the case, in general. Your witness must be prepared for questions that will come from your opposing counsel. People say that it’s impossible to win a case during deposition, but it is possible to lose a case during deposition.

And that’s where Elizabeth comes in, ensuring that your witness understands their place in the larger scheme of the trial and telling their truth in a way that is comfortable for them and beneficial to your case.


Trial Preparation

For witness testimony at trial, your witness must have an idea of what to expect and how changes during trial may affect their testimony.

That’s why Elizabeth works directly with your witnesses, making sure they are familiar with all relevant exhibits, prepping them for questions from opposing counsel, educating them on the impact of their prior deposition testimony and ensuring they will make a favorable impression on the jury.


How we work together:

Step 1: Schedule a free Consultation Call with Elizabeth (30 minutes)

  • How does the preparation process work?
  • What type case?
  • What type of challenge is the client facing?
  • What is the time frame? Any restrictions?

Step 2: Proposal

Step 3: Schedule the Client Preparation Meetings

  • Elizabeth can work with office staff or directly with client for scheduling
  • Meetings are usually conducted in the 7-10 days before the deposition or trial
  • A combination of Zoom and in-person meetings are available

Step 4: Case Review

  • Elizabeth will do a file review to prepare & better understand case
  • Craft questions for role play

Step 5: Final Q&A call with retaining lawyer (15 min)

Step 6: Client Preparation Meetings

Step 7: Debrief Call with retaining lawyer

"This was the toughest client I have had in my 20-year career. She had extreme worry about her deposition and that was multiplied by the fact that her injury was severe. If I tried to give the client direction, we would fight. Elizabeth took the weight off me and, even the client, completely. Elizabeth was caring and attentive to her needs – taking extra time to listen to the client. Elizabeth provided guidance and tools to help the client with her memory. No chance I could have done that. At her deposition, she followed the truths and the defense attorney was perplexed at her ability to handle the difficult topics. After the deposition, my client was thankful for the help Elizabeth provided."

~ Hunt Bonneau | Bonneau Law
Dallas, Texas

Why you need trial lawyer Elizabeth Larrick

Elizabeth Larrick has a passion for preparing witnesses to their fullest ability.

This passion began in 2012 after many failed client depositions. Elizabeth was frustrated by the traditional preparation methods, and attended a Don Keenan seminar on Depositions.  She saw Mr. Keenan’s method and took to it immediately. She studied and applied the witness preparation method on her own clients. She continued to perfect and master the method over the years to come.

Then in 2016-2017, she took part in a one-year fellowship with the renowned Keenan Law Firm in Atlanta, Georgia, allowing her the opportunity hands-on trial experience. Her role allowed her to step into trials, prep witnesses and put them on the stand in three important cases (medical malpractice in Louisville, Kentucky, a premises liability in Seattle, Washington and a wrongful death in Las Vegas, Nevada). She learned skills for trial management, case themes, focus groups, jury selection and case development.

Since returning to full-time work at her own law firm, Elizabeth has used that experience to ensure that each of her clients’ needs and concerns are individually met in time for trial. But also to assist other lawyers directly with challenging clients and cases.

She continues to teach lawyers on Witness Preparation at the Keenan Trial Institute. She served as the Co-Dean of Witness Preparation and Advanced Witness Preparation as Co-Dean for over four years. She is regularly invited to speak on the Witness Preparation topics at Keenan Trial Institute seminars over the years and other trial lawyer associations. Her goal is to help other trial attorneys work to empower their clients and strengthen their case.

Schedule a CallMeet Elizabeth
elizabeth larrick - Larrick Law Firm - austin texas

Want to hear from Elizabeth?

Elizabeth started her own podcast Trial Lawyer Prep to talk all things witness prep. Listen below to a few episodes on witness preparation.

Contact Elizabeth today

Elizabeth is here to help secure your case by strengthening your client through their ability to tell their story and crush cross examination.

Contact Elizabeth today to answer your questions about structured witness preparation.


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