The most important element of any case is your client – she is exhibit A. The jury will be highly influenced by how well your client tells her facts at trial and whether she appears sincere. In most situations, your client has not previously been involved in a lawsuit and is consequently nervous about testifying at trial. I had one client in particular who was extremely nervous. I knew I had to calm her nerves so she would be comfortable in front of the jury. I scheduled three pre-trial meetings with her.
During the first meeting, we sat down and reviewed all statements she had previously provided, including her deposition transcript, in great detail. We also discussed what happens throughout the trial. In the second meeting, I had my client meet me at 8:00 a.m. and then drove to the courthouse, acting as if we were going to trial. We entered the courthouse and entered an open courtroom, where I introduced her to the courtroom’s layout. I then instructed her to take the witness stand and began my direct examination of her with the intention of making her comfortable so we could have a relaxed conversation in front of the jury. For the third meeting, we returned to the courthouse and modeled the events from the second meeting.
One visit may be enough for some clients. If your client still seems uneasy, have her go through the same process a second or third time. I followed these steps and when I presented my client at trial, she appeared very comfortable and was subsequently able to communicate her facts to the jury with little apprehension. We held a conversation and the jury was able to follow along. In the end, the jury ruled in my client’s favor.