Preparing witnesses .—A definite understanding must 
be had with each prosecuting witness as to exactly what 
he will testify to, based both on what he can testify to 
and on what portion of this you will want him to testify 
to. His testimony must then be gone over, to insure both 
that he will tell the exact facts and that his statements 
will not be open to objections by the defense, which 
might destroy the effectiveness of the evidence, as well 
as mix up the witness; but care should be taken to avoid 
anything that can be misconstrued as “coaching,” or 
“framing” of evidence. In connection with this work 
certain points are always legitimate, and should be clearly 
impressed upon witnesses. 
1. On direct examination they should only answer 
questions, not explain. This will let the questioner be 
the judge of what and how much shall be said. 
2. Except when it is based upon a written record, 
which can be referred to in court, testimony should not 
be too exact, especially as to time, but should be qualified 
by some such phrase as “to the best of my recollection.” 
This will prevent giving a loophole for its discrediting 
by the defense on any points of nonessential exactness. 
If exactness is required on any point, see that you have a 
record to make it so. 
3. When testifying from a notebook or other record do 
not read word for word, but let the record be referred to 
as a guide or help to the memory on details. This is 
always permissible, whereas direct reading may raise 
annoying objections to the admission of the record in 
evidence. 
4. Photographs must be introduced in evidence by the 
person who made them. Enlargements must be accom¬ 
panied in evidence by the originals from which they 
were made. 
Other points may need attention, of which the following 
may be mentioned: 
5. Testimony of conversations at second hand can not 
be used in court. 
6. Testimony respecting a confession should usually 
relate the conversation and the fact that it was voluntary, 
