•  Truth:  Tell the truth. Lies and half-truths, even on seemingly unimportant matters, are frequently exposed and will destroy your listener's confidence in you and your case.

•  Pace:  Don't jump at answers. Pause after the question to permit objections and to frame the answer.

•  Short answers:  Give short, direct answers.

•  Volunteering:  Don't volunteer additional information.  This frequently provides leads for the other lawyer and helps their preparation for trial.

•  Argument: Don't argue. Argument is the lawyer's life work and most lawyers are better at it than you are.

•  Jokes.  Don't tell jokes of any kind - they look silly, as if you are making light of the other side's problems.

•  Demeanor:  Keep cool! Don't lose your temper - "Those whom the Gods would destroy, they first make mad."

•  Skepticism:  Be skeptical of the other lawyer. He or she cannot possibly be your friend, no matter how nice her or she seems. Watch out for:

•  Summaries at the beginning of questions.

•  Long compound questions.

•  A rapid, cheerful pace.

•  Comprehension:  Don't answer a question you don't fully understand; don't speculate or guess at an answer - a guess is not evidence for your side, but it might be for your opponent.

•  Memory:  If you don't remember, say so; a loss of memory can frequently be refreshed.

•  Don't help your opponent by asking questions or asking for irrelevant documents.

•  Read all pages.  If you are shown a document, take time to read it all, even if everyone is bored to death waiting for you.

•  Don't telegraph uncertainty.  Try not to say things like "honestly" or "to tell you the truth"- they create a negative inference as to the rest of the testimony and indicate to the careful listener that the witness is actually in some doubt on the matter;

•  Superlatives:  Never say "never" (or "always"); indeed, try to avoid all superlatives. They invite use later in cross-examination.

•  Don't get railroaded.  When the lawyer is rolling along rapidly, take a moment to pause and think, or take a moment to examine a document. Don't adopt your examiner's rhythm.

•  Stick to testifying:  Let your lawyer take care of procedural details such as objections, production of papers, recesses, arguments with opposing counsel, etc.

•  Stay with the preparation.  Don't dream up a new theory on the spot.

•  Finally, who cares if the other lawyer is upset with your answers?  Just tell the truth and let the facts take care of themselves.