90% OF OBJECTIONS TO YOUR TESTIMONY ARE OF TWO TYPES:
YOUR ANSWER IS A CONCLUSION, OR
YOUR ANSWER IS NON-RESPONSIVE
AVOIDING CONCLUSIONS
DON�T STATE AS A FACT SOMETHING YOU DON�T KNOW TO BE A FACT
LIMIT YOUR TESTIMONY TO THINGS YOU KNOW
DON�T MINDREAD
YOU CAN�T TESTIFY TO WHAT OTHERS SEE, HEAR, FEEL, THINK OR WANT
THE WRONG WAY:
Q: WHAT DID HE DO THEN?
A: HE LOOKED BACK, SAW ME AND TRIED TO RUN AWAY
THE RIGHT WAY
Q: WHAT DID HE DO THEN?
A: HE LOOKED DIRECTLY AT ME AND BEGAN TO RUN
SOME WORDS ARE ALWAYS CONCLUSIVE
NEVER USE THEM IN REPORTS OR WHILE TESTIFYING
SEE LIST ON PG. 106
GIVING RESPONSIVE ANSWERS
THE WRONG WAY:
Q: DO YOU WANT TO GO OUT TONIGHT?
A: I�VE GOT A LOT OF HOMEWORK TO DO
THE QUESTION CALLED FOR A YES OR NO ANSWER
THE RIGHT WAY:
Q: DO YOU WANT TO GO OUT TONIGHT?
A: NO
Q: WHY NOT?
A: I�VE GOT A LOT OF HOMEWORK TO DO
ANSWER YES OR NO QUESTIONS WITH A YES OR NO (OR AN UNEXPECTED QUALIFIER)
ANSWER A QUESTION BEGINNING WITH �WHERE� BY GIVING A LOCATION (IF YOU KNOW)
IF A QUESTION BEGINS WITH �WHO,� TALK ABOUT A PERSON (IF YOU KNOW)
IF A QUESTION ASKS �WHEN,� GIVE A TIME, DATE OR REFERENCE TO ANOTHER EVENT (IF YOU KNOW)
IF A QUESTION ASKS �WHY,� GIVE A REASON OR EXPLANATION (IF YOU KNOW)
BE AS DIRECT AS YOU CAN, THEN STOP TALKING
HANDLING CROSS-EXAMINATION
THE DEFENSE LAWYER�S MOST IMPORTANT TASK IS TO DESTROY YOUR CREDIBILITY
HE STARTS BY PICKING APART YOUR REPORT
FREQUENT OBJECTIONS MAY JUST BE FOR THE PURPOSE OF DISRUPTING YOUR TRAIN OF THOUGHT
IF WHAT�S SAID IS NOT ACCURATE, SAY SO
WATCH OUT FOR BLUFFS (SUCH AS THE EYEPATCH)
DON�T QUANTIFY BRAIN CHEMISTRY
BEWARE THE MINUTE OF SILENCE
JOHNNY CARSON�S EARLOBES
YOU CAN CONTROL THE SPEED OF THE QUESTIONS
IF IT�S NOT A QUESTION, DON�T RESPOND
DON�T GUESS
DON�T APOLOGIZE FOR YOUR REPORT
IT�S NOT POSSIBLE TO RECORD EVERY DETAIL IN YOUR REPORT
YOUR REPORT IS A SUMMARY OF WHAT SEEMED IMPORTANT AT THE TIME
DON�T APOLOGIZE FOR DOING YOUR JOB
REMEMBER OFFICER POMPEO (HOW HARD DID YOU HIT HIM? JUST AS HARD AS I COULD)
IF ASKED A COMPOUND QUESTION, SAY YOU DON�T KNOW WHICH THING YOU�RE BEING ASKED TO ANSWER
IF MISQUOTED, SAY SO