Attorneys often lack the time to prepare every witness thoroughly; even when they do carefully prepare a witness, the witness may make statements the attorney has never heard before and refuse to repeat previous statements. Only thorough preparation and courtroom experience will give an attorney the confidence and presence of mind to handle such a witness. Therefore, the attorney should learn how to apply the Federal rules, which are intended to be read, interpreted, and applied in conjunction with each other, not individually. Attorneys can lead witnesses they are impeaching under the guise of refreshing their memory. They may ask leading questions generally where the witness is hostile, unwilling, or biased; where a child or adult witness has communication problems; where the witness has recollection problems; and when preliminary matters must be established. It is crucial to know when to obtain permission before asking leading questions and when to simply beg forgiveness after already leading. The attorney should also wave the theme of the case into the questions and use short, simple, pointed questions. They should also visualize their examination and recognize that the attorney's job is to be the leader throughout the testimony. 3 reference notes