I tell the client it is proper to say, “I don’t know,” if the client doesn’t know. I say, “Don’t guess and don’t add anything that is unnecessary to give a full and honest answer. If you make a mistake, simply say you made a mistake. The truth is always the safe port, even when it hurts. Don’t be afraid of the cross-examination. I will be there to protect you against any improper questions. And one thing for sure. Be absolutely as fair and friendly to the cross-examiner as you are to me. Remember the three Cs.”
