Jordan
Transcript Coach
8
Weaknesses
3
High Risk
5
Patterns
Testimony Weaknesses & Coaching Opportunities
1. Overstatement Pattern — "Never" and "Always"
🔴 High Risk
Problematic Testimony
"Nobody ever told me about asbestos being dangerous."
"I never received any safety training whatsoever."
"They never gave us any protective equipment."
"I never received any safety training whatsoever."
"They never gave us any protective equipment."
Pages 23, 31, 45
Coaching Recommendation
Absolutes invite impeachment. Train witness to use qualified language: "I don't recall receiving..." or "To the best of my memory..." Defense has documents contradicting each of these absolute statements.
2. Memory Confidence vs. Documentation Gap
🔴 High Risk
Problematic Testimony
"I remember exactly—it was about 10 years I worked there."
"I started in 1976, I'm sure of it."
"I started in 1976, I'm sure of it."
Pages 19-20
Coaching Recommendation
W-2 records show 1978-1983 (5 years). High confidence + wrong facts = devastating. Prepare for document confrontation. Better answer: "It's been many years—I'd have to look at the records."
3. Volunteered Information
🟡 Medium Risk
Problematic Testimony
"And another thing—my friend Bobby Thornton worked there too and he can tell you the same thing about the conditions."
Page 54
Coaching Recommendation
Never volunteer witness names. Thornton's deposition contradicts this—he confirms receiving respirators and training. Witness opened door to devastating impeachment.
4. Symptom Onset Exaggeration
🟡 Medium Risk
Problematic Testimony
"I started having breathing problems right after I left Atlantic Maritime in 1985."
Page 67
Coaching Recommendation
Medical records show first respiratory complaint in 2019—36 years later. While consistent with mesothelioma latency, the exaggeration damages credibility. Stick to documented facts.