The important witness in civil litigation will be examined both at the oral deposition and at trial, and the preparation for each is different. Regarding depositions, witnesses must be taught that they are dictating an important legal document. A primary rule for the deposition is that the witness must wait 5 seconds between the last word of each question and the first word of each answer. During this time, the witness should insure that the question is understood and only then compose the answer. Witnesses must be informed of the differences between knowledge, hearsay, and surmise. The attorney should remind the witness of unknown facts during the events in suit, because much information may have been learned after the fact. At the first briefing session, the attorney should get to know the witness, understand the witness' perspective on the events in suit, and start identifying the areas where the witness needs the most help. The second briefing conference covers the relevant subject matter though casual questioning, followed by a serious examination under laboratory conditions. If another lawyer familiar with the case is available, the second lawyer may take the witness through the second examination to give the client's attorney the opportunity to watch and evaluate. Preparation for the trial can be helped through a videotaping of the witness' testimony. Preparation should be balanced between direct examination and cross-examination. The practice examinations may be divided between two or more lawyers.