A common occurrence in the trial of an action is a party, compelled by the exigencies of the party’s case, calling as a witness a person who has knowledge of facts favorable to the party’s case but whose testimony regarding the matter in issue may be contrary to what was expected and harmful to the calling party’s case.

Such a situation may occur where the witness is an adverse party or a non-party witness who may be unfriendly. Such a witness may provide damaging testimony. For discussion of this concern, see Barker & Alexander, Evidence in New York State and Federal Courts (2d ed) §6:32. How may the attorney neutralize or minimize such testimony?