Los Angeles, CA commercial litigation attorney Brian M. Grossman explains how he prepares for trial. He shares that he prepares for trial by creating witness examination lists and detailed outlines. For each witness, he maps out the general topics and questions he intends to cover. He avoids writing questions verbatim, knowing that doing so makes it too tempting to simply read at trial. Reading directly from a script, he believes, fails to hold a jury’s attention.

Instead, he relies on outlines, which allow him to stay flexible and engaged. When a question is supported by evidence—such as deposition testimony or documentary proof—he cites it in his notes. That way, he is ready to refresh a witness’s recollection if needed, or to impeach an opposing witness by confronting them with their deposition testimony or a key piece of evidence.