Keenan Explains Company Witness Prep for IADC

Shook Partner Matt Keenan has authored an article for the International Association of Defense Counsel's newsletter exploring best practices for preparing company witnesses for trial. Keenan describes his "PLEASE" formula for ensuring a company witness understands the task:

  • Prepare
  • Listen
  • Exercise control
  • Accept the obvious
  • Stay in your area
  • Emotion is acceptable

Keenan also warns attorneys to prepare their clients for "gotcha" questions—those questions designed to make a witness look foolish, cruel, or unknowledgeable—and to review possible responses to documents presented to witnesses during depositions.