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During the second phase of client testimony preparation, sometimes there’s a big miscommunication between the clients and the lawyers. Lawyers ask differently in deposition than they would in any other kind of conversation. Therefore, it warrants some education so clients can go through it smoothly. 


In Phase 1, we talked about getting into the right mindset, which applies to clients and trial lawyers. Today, we look into Phase 2, which also refers to the organizing phase. This phase does not mean crafting, shaping, molding, or woodshedding any testimony. Resist the urge to craft and change your client’s words to make them sound better or to make their answer the question more clearly. Instead, make sure you organize what the client already has in their brain and what they already know so clients can see the bigger picture concerning the questions they get. 


There is power in the truth, and it is all you are doing in this phase – to help clients see that and organize it for them. 


In this episode, you will hear:

  • Challenges trial lawyers have in this phase
  • The 3 main purposes of a deposition
  • The power of telling stories
  • Why you shouldn’t be changing the client’s words

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Supporting Resources:

Larrick Law Firm


If you have a question or comment, please let me know: [email protected] 


Episode 014: Phase 1 of Client Testimony Preparation 

Episode 011: Focus Groups: What Do You Get?



Episode Credits

If you like this podcast and are thinking of creating your own, consider talking to my producer, Danny Ozment.

He helps thought leaders, influencers, executives, HR professionals, recruiters, lawyers, realtors, bloggers, coaches, and authors create, launch, and produce podcasts that grow their business and impact the world.

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