Direct examination is the harder skill, because the witness rather than counsel must carry it.
No leading questions on substantive matters. Use who, what, when, where, how and then what happened. Leading is permitted on background, on undisputed matters and to direct attention to a subject.
Structure chronologically in most commercial cases, with a short orientation first — who the witness is, their role, and why they know what they know.
Set the scene before the event. A jury cannot follow testimony about a meeting without knowing who was present and what preceded it.
Use documents as the spine. Establish the foundation, publish the exhibit, and have the witness explain it. Documents pace the testimony and give the jury something to hold.
Headline transitions. Announce the subject change so the jury can follow.
Let the witness explain in their own words. Testimony that sounds rehearsed is discounted, and the most common cause is a witness delivering counsel’s sentences.
Draw the sting. Bring out the weaknesses on direct rather than leaving them to cross.
Preparation. Cover the substance, the documents, and the manner — pausing, listening, answering only what is asked, and admitting what is not known.