A few years ago I represented the children of a deceased father. His wife had been dead for several years before he died. A lawsuit was filed by a woman acquaintance against his estate.  She claimed she was entitled to a large share of his estate on the basis of multiple claims including a promise to leave her money and other similar claims. She lost and eventually was required to pay my clients costs and attorney fees. I had a collection of notes on the issue of credibility from which I would select what I thought appropriate or use as a visual reminder of ideas. Perhaps something her will be helpful. Here it is in rough draft form:

CREDIBILITY                        

A. ARGUMENT

Concept:  In this case, a man’s girl friend asks us to ignore his valid will leaving his estate to his only children because she wants it all for herself, but if she can’t have all of it, she will take $1.5 million, but if she can’t have $1.5 million she will settle for $1 million.

Phrases:

• she asks us to ignore undisputed facts and common sense
• The quest for money darkens the sense of right & wrong
• Greed for money is infectious
• Greed is the master of gain with deceit. It’s tools are dishonesty and lies
• Facts do not cease to exist because they are ignored
• You can’t have it both ways
• The blurring of facts and fantasy
• Facts which can only be ignored by putting both fingers in one’s ears and humming loudly
• Their spin on the facts is like trying to drive a car by looking in the rear view mirror
• They use the tax returns like an accounting slight of hand

B. Phrases

    1.  "oh what a tangled web we weave when first we practice to deceive"
    2.  A chain is only as strong as it weakest link
    3.  Actions speak louder then words

C. QUOTATIONS

    1.  Their claims amount to nothing more then a collection of dubious facts, half truths and no truths – what ordinary people call lies 
    2.  Let not the facts get in the way of a perfectly good theory
    3.  Difficult evidence to ignore, unless your 11^th commandment is ignore the facts
    4.  A magnetic compass should always point north and a moral compass should always point to the truth
    5. When you pull back the curtain what you find are fundamental flaws in their claims
    6.  It’s like a david copperfield magic act – all smoke and mirrors
    7.  Rbuaiyat of omar khayyam: "the moving finger writes and having writ moves on; nor all they piety nor wit shall lure it back to cancel half a line; nor all thy tears wash out a word of it"