I prepare for trial by creating witness examination lists and witness examination outlines. And, I go through each witness, I outline the general topics and questions that I intend to ask that witness. I don’t do it verbatim because that is too tempting for you to simply read at trial. And, you don’t wanna be reading at trial. You don’t wanna be looking down and reading a question verbatim, it doesn’t hold the attention of a jury.

So, I do it in outline format. And, if my question is supported by evidence such as deposition testimony or documentary evidence I site that as well in case my witness needs to have his or her recollection refreshed. Or, if I need to impeach an opposing witness by calling out their deposition testimony or by showing them a piece of evidence that I can impeach them with.