1. Give the psychologist you wish to testify on behalf of your client more than two hours notice especially when she has no idea you're going to call her to the stand. Doubly so when (a) she has no idea she is going to be called as a witness and (b) the courtroom is located in the next county. We do have other clients to consider. We do have several years worth of notes to review. And we might need to fill our gas tanks.
2. Give the correct address of the courtroom. There is a difference between Chestnut and Chester Streets.
3. Introduce yourself when you come out to find the witness. Looking at two waiting therapists, neither of whom have ever laid eyes on you, and asking, Who wants to go first? doesn't cut it. I mean, dude, you want us on your side.
4. Ask one question at a time. Four questions wrapped into one is a sure way to annoy the witness and the judge. It's also a way to get an answer you weren't looking for. We are talking about the future of little kids here, not whether some corporation has to pay a two-bit fine.
5. Don't ask questions that don't have double negatives in them. Meaning, ask questions worded in the positive. It's a whole lot clearer. We witnesses really don't enjoy saying, I'm sorry, that question is too convoluted for me to answer several times in a row.
6. Show the slightest bit of appreciation for the psychologist who, at a moment's notice, rescheduled her afternoon appointments, drove 40 miles, skipped lunch, and, unlike yourself, isn't getting paid.
7. It would be a whole lot more fun for everybody involved if you acted a little more like the attorneys on Boston Legal. Go for edgy and a lot less repetition. One, we'd know what to expect. Two, the judge might actually pay attention. And three, novice expert witnesses like myself might actually look forward to testifying instead of dreading it with every ounce of our being.
Note to the rural county court stenographer? You keep rockin' those rhinestone flip flops.
