Witnesses should be evaluated on their appearance and the first impression they create; the content and extent of their useful knowledge; and their ability to communicate. The plaintiff's attorney can help witnesses improve their appearance, delivery, and communication skills. The attorney's relationship with witnesses when preparing for deposition and trial is described in detail, along with suggestions for presenting lay witness testimony. Lay witnesses humanize the trial. They should be encouraged to describe spectacular or gripping events, for the jury will usually find their stories more persuasive than photographs. If lay witnesses are not effective, an attorney should not use them at trial. However, the effective presentation of damage testimony through a lay witness is a simple and powerful way for an attorney to plead his case. 5 footnotes.