Child Custody Witness Guide 
for Deposition or Court 

Includes Video Deposition

Table of Contents

1: Why Me?
How Subpoenas Work
I Don't Belong Here
2: What Should I Do Now?
Reasons You Want to Testify
Black/White or Shades of Gray
Your Agenda
Skeletons in Your Closet
Defense Against Attack
Worst Reasons to Testify
3: Refusing to Testify
When You Are in Contempt
Failure to Appear
You Don't Want to Testify
Can't Pay Witness to Not Testify
Failure to Disclose Sources 
4: Unusual Situations
Switching Sides
Stealth Witness
Whose Case is This Anyway?
5: What is a Witness?
Reason for a Witness
Burden of Proof
They Know You Are Coming
Types of Witnesses
The Three Most Important Rules
6: Discovery
Production of Documents
Admissible Evidence
Fruit of the Poisonous Tree
Time Line
7: Evidence
I Am Not Involved
Demonstrative Evidence
E-Mail & Message Boards
Linguistic Sleuthing
Tape Recorder
Video Tapes
8: Your Testimony
Testimony Terror
Types of Testimony
Self-conscious Witness
Self-confident Witness
Content of Your Testimony
Did You See What I Saw?
Purpose of a Pre-Trial Meeting
Your Assignment
Lies, Damn Lies, and Statistics
Last Review
Aid to The Enemy
9: Perjury
Variations of Oath
Recalling a Witness
Subordination of Perjury
False Swearing
Conflicting Truths
The Court Will Call a Liar a Liar
Proof or Poof
Defense Against Lies
Using Their Lies Against Them
Examining Witness Statements
Non-Fatal Flaw
Your Lies
Start Repairing the Damage
Sue for False Accusations
10: Your Visual Impact
First Impression
Halo Effect
Court Attire
Especially for Men
Especially for Women
Important for Men and Women Body Language
Defensive Behaviors
Positive Behaviors
Aggressive Behaviors
Delay Behaviors
News Flash Junkies
Friendly Fire
11: Deposition
What is a Deposition?
Types of Depositions
Audio and Video Admissibility
Reasons for Deposition
Pre-Deposition Meeting
Second Pre-deposition Conference
Rules of Deposition
Costs for Deposition
Best Time to Be Deposed
Second Deposition
Personal Preparation
Instructions from the Opposition
Example of Instructions
Deposition Outline Form
During Your Deposition
Ending Your Deposition
Check Your Deposition
Deposition Format
Correcting Mistakes
Objection to Corrections
12: Video Deposition 
The Court Case of the Future 
Fear of the Camera 
Showing the Pain
Challenging Video Deposition
Synchronized Deposition
General Rules
Important Differences 
Deposition Induces a Trial
FRCP for Video Deposition

13: Confidentiality
Your Children or Your Parents

Your Spouse
Professional Services
Medical Records
Business Owner
Breach or Compromise
14: Work-Related
Accident Investigation
Accountants and Bookkeepers
Conciliation Court
Day Care Workers
DNA - Genetic Testing
Drug Tests
Legal, Medical, Scientific Transcribers
Lie Detector Test
Liquor Store
Medical Review Consultants
Paralegal Service
Security Patrol
Spy Shops
State or Federal Employee
Travel Agents
15: Experts
Loose Cannon
What Experts Can Do
Experts Only, Please
Physician, Consultant, Expert
Physician's Responsibility
Expert's Responsibility
Some Experts Are Prostitutes

Before Court
Mock Trial Court
In Court
Questioning to Expect
Traps to Avoid
Opposition Expert
Your Opinion of Their Expert
Avoid Metaphors
Challenging Expert Testimony
After Testifying
16: Attorneys
Attorney Only Protects the Client
Won't Be an Accessory
Good Old Attorney System
Attorney Types
Ol? Buddy
Faster Than a Speeding Bullet
Crazy Quilt
Word Butcher
New Kid on the Block
Mad Dog Attorney
The Mad Dog During Deposition
Handling the Mad Dog In Court
Silent Waiter
The Exposer
17: Judge
Perception of Hierarchy in Law
Hierarchy List
Welcome to the Hotel California
Types of Judges
Good Judges
Judges? Influence
Opinions About Judges
Cannot Do with the Judge
Judicial Immunity
Abuse of Discretion
18: Traffic Court
Photo Traffic Signal Violations
Officer No Show
When You Get To Traffic Court
Traffic Court Guilty
Traffic Court Fines
Traffic Court Not Guilty
Traffic Court Trial
Traffic Court Penalties
Traffic Court Appeal
Traffic Court Rights
Best Way to Avoid a Ticket
19: Civil or Criminal Court
What Actually Happens
Types of Courts
U.S. Supreme Court
Appellate Court
State or Superior Court
Courts of Limited Jurisdiction
Military Court
Tribal Court
Grand Jury Trial
Types of Cases
Civil Cases
Criminal Cases
Administrative Cases
Equity Cases
Are All Court Appearances Equal?
Know the Legal Arena
Prepare for Your Day in Court
Five Days Before Court
The Night Before Court
Court in the Morning
Court Later in the Day
Your Day in Court
How to Act in Court
Court Joker
Smoke and Mirrors
Exclusion from Courtroom

During Your Courtroom Testimony
Confidentiality - Court
20: Jurors
Who may serve as a juror?
Choosing the Jury
Prospective Juror Questionnaire
Jury Consultant's
Criminal or Civil
Jurors' Oath
Stages of Trial
The Arguments of Counsel
Communicate With The Jury
Judge's Charge to the Jury
Conduct During the Trial
Shadow Juries
In the Jury Room
After the Trial
Juror Post Trial Interviews
21: Questions?
Types of Questioning
Direct Examination
Cross Examination
Types of Questions
Multi-Part Questions
Take-Me-Along Questions
Open Questions
Leading Questions
Commonsense Questions
Hypothetical Questions
General Rules of Objection
Objections to a Question
Argumentative Question
Compound Question
Lack of Foundation
Dodging Tricky Questions
22: Answers
Don't Worry About Looking Stupid
Rating Scale Questions
Question By Design
As a Lamb to Slaughter
Safe Answers
Not Sure! Not Sure?
Do You Know It All?
Absolute No No's
Witness Impeachment
23: Children Testifying
Oath of Truth for Children
Child's Own Attorney
Alternatives to Open Court
Ten Tips to Help Children
Children and Confidentiality
Children Feel Guilt
Child's Need to Know
Why Children Don't Lie Well
Don't Tell Children to Lie
Who Will Know the Child Lied?
Children Testifying in Court
Competence of Child to Testify
Knowing Truth from Lie
Recording a Child's Testimony
Challenging a Child's Testimony
Suppress Child's Testimony
Fear, Bias, Prejudice or Interest
24: Pre and Sentencing
Determining Sentence

Mandatory Sentencing
Prosecution and Defense

Arguments on Sentence
25: Sentencing Statement
Victims? Statement
Preparing a Statement
Time Limit
Recommend a Sentence
Supporting Statements
Inflammatory Statements
Examples of Statements
Victim Statement #1
Victim Statement #2
Convicted Statement #3
Victim Statement #4
Convicted Statement #5
Convicted Statement #6
Convicted Statement #7
Victim Statement #8
Convicted Statement #9
Convicted Statement #10
Convicted Statement #11
Victim Statement #12
Important Considerations
Order of Presentation
Verdict by Judge or Jury
26: Appeal the Threat
Old Information Only
You Won't Have to Be There
Glossary of Terms

Child Custody Witness Guide

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Since March 1992