Dear Carolyn,

I have a court date coming up. I am fearful about being questioned by the other attorney, who seems like a bully to me. The case is about the custody of my child. How do I handle the bully lawyer when he asks me questions?


Carolyn Answers,

Being a witness is not always easy, but there are some guidelines that, if practiced, will make your experience better. Your credibility will be enhanced. Many witnesses are confused about their “job” as a witness. The job of a witness is not to anticipate where the attorney is going with the questions. There are four rules of being a witness.

Rule one: Listen to the question. Sounds easy, right, but this is the hardest part. The classic question is: “Do you know what time it is?” What is your answer? Many folks look at their watches and give the time, but that is not the question. “Do you know the time” is a “yes” or “no” answer. Then the witness should wait for the next question.

Rule two: Understand the question. Make sure you know what you are answering. Does the question have two parts? Compound questions may be objected to by your attorney, so if you hear the objection: “Objection: Compound Question,” take note that the question has two parts. If the judge allows the question, repeat back the first half of the question with the answer, and then repeat the last half with the answer.

Rule three: Answer. Start with a yes, no or I don’t know, if that question asks for that type of answer. Then you may explain your answer if an explanation is necessary.

Rule four: Shut up after you have answered. Cross-examination is not the time for a non-stop answer.

With practice with these rules, you will be a credible witness.


Send your questions on family law and divorce matters to “Ask Carolyn…” at, or P.O. Box 9023, Greensboro, NC  27427.  Please do not put identifying information in your questions.  Note that the answers in “Ask Carolyn” are intended to provide general legal information, and the answers are not specific legal advice for your situation.  The column also uses hypothetical questions.  A subtle fact in your unique case may determine the legal advice you need in your individual case.  Also, please note that you are not creating an attorney-client relationship with Carolyn J. Woodruff by writing or having your question answered by “Ask Carolyn…”