For Mary Jo Barr, a veteran trial lawyer with the Office of the Public Defender of San Diego County, the first rule of witness preparation for a deposition is pretty cut-and-dry: The witness needs to know to tell the truth, whether it’s good or bad for her client.

“One of the things I like to tell my witnesses that I’m preparing is that, look, mistakes happen,” said Barr, speaking during the National Institute for Trial Advocacy’s first webcast of 2021. “Mistakes I can fix. What I can’t fix—what I can never fix—is a lie.”

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