Speaker 1: I'd like to give you some tips for preparing for trial. First, for each element of your case that you have to prove or disprove, figure out what the particular elements are that you have to prove. Then break it down as to who or what documents you will utilize in order to prove or disprove those elements. Then you determine how you will obtain admission of the evidence over objections. You have to figure out if there's documents, how are you going to get the documents in over objections concerning hearsay. In other words, in order to proceed successfully, you must introduce each element of your case, prepare for each element of your case considering the rules of evidence. Also prepare an outline of what your opponent must prove and figure out how he or she will prove their elements. Then determine what objections you will raise as to that evidence. One easy way to get documents introduced is through a stipulation. Figure out what documents you wish to introduce. Make a list of them. Go to your opposing counsel and ask them if they will stipulate to the authenticity of the documents. Not to the admissibility, just to the authenticity. That gets you beyond any hearsay objection. If you're unable to obtain such stipulation, you can go to the court and ask the court to set a deadline in which to object to the authenticity of the documents. If you're able to reach an agreement with counsel, make sure you document it adequately. Document by document, witness by witness. Usually those sorts of procedures are required outside of bankruptcy. In bankruptcy, there are lots of different types of proceedings such as objections to exemptions, objections to claims, motions for relief from stay, etc. that are not necessarily covered by those rules. That is why you should go obtain a stipulation or obtain a court order. If all else fails, remember you must subpoena appropriate witnesses and witnesses who have documents in order to obtain their admission. Make sure you have an idea of which witnesses are going to be used to introduce each element of your case. Prepare your witnesses. Make sure you go through each and every question you're going to ask and prepare an outline as to what you expect their answers will be. Many times, witnesses will answer you but will forget a couple of the points you want to make. If you have your outline as to what points you want them to make, then you can go back and ask them again, what about this element? By the way, one of the most difficult objections that attorneys have to deal with are objections to leading questions. Here's a trick on how to avoid that. Ask what, if any, or when, if ever, or who, if ever, did such and such. That will get you beyond any objections to leading questions. Make sure your witnesses read their depositions before trial so they don't inadvertently contradict themselves. Do not rely upon key witnesses appearing at trial. I can't tell you the number of times that I've had parties come in and say, I assumed the party representative of my opponent was going to be here, and that witness has not appeared, has not shown up, and that party has lost their case because they were relying upon the opponent's witness being at trial. If you need that witness, make sure you have an agreement in writing from opposing counsel that that witness will appear or subpoena that witness. Most attorneys don't understand how to raise an objection. You first stand. The first words out of your mouth are objection. Then state the two or three words as far as that would indicate the type of objection. Objection hearsay, objection leading, etc. If the judge wants more, he or she can ask for it. Make sure you object as soon as the question is asked and before the answer is given. Otherwise, you may be waiving that objection. Finally, don't use pronouns. Don't let your witness use pronouns. Always be thinking about an appeal and what an appellate judge is going to read on the record. Is he or she going to know what he or she, who he or she is? One last point I'll tell you is Judge Michael Williamson from the Middle District of Florida Bankruptcy Court has published a practical evidence manual. It is linked. There's a link in our website and a link in the Middle District's website concerning this. It is an invaluable resource for you. Thank you.