Extraneous offense attempts by the State 3. Badgering by the State. You can actually prepare your witnesses and with your most trusted, set traps for the prosecution to step right in the middle of. You want to use your witnesses to make the jury or the judge a part of the family. You want tears, crying, weeping, begging for forgiveness, all coming out.
Emotion can be a deadly weapon to the State.
The State is not going to jump all over an emotional witness, begging for forgiveness, begging for mercy, and pledging his loyalty to your client. You want to make sure that you have every facet of life of your client impregnated with assistance from family, clergy, friends, employer, etc. Finally, the most time in preparation of witnesses should be spent with your client. Develop your plan and have him know it backwards and forwards, with an unrelenting pledge to make a positive contribution to society and begging for leniency. I have never been able to prepare a client in less than two hours of mapping out, practice, and preparation for him to be crossed.