Techniques for preparing the lay witness include a rehearsal of direct and cross-examination recorded on tape, followed by a playback and attorney comments. Some guidelines for the attorney are to ask questions on direct that elicit the precise information desired, not to repeat questions which receive favorable answers, and to bring out in direct issues likely to be addressed in cross-examination. A likely cross-examination from opposing counsel should be rehearsed with the witness. Preparation should strive for clarity, crispness, and conviction in the witness' testimony. Guidelines for the attorney in cross-examining an opponent's witness are to use means that raise doubts about the witness' credibility and to use the witness' deposition transcript to expose inconsistencies in the witness' story. The preparation of expert witnesses involves instruction in techniques for making complex information understandable to the lay jury. The cross-examination of an opponent's expert should expose uncertainties, qualifications, and alternatives to the expert's opinions or theories.