13. TO ALLOW THE DEFENDANT TO TESTIFY
Americans love to see the defendant get up and say "I didn't do it". If your client can truthfully testify to any matter which is in controversy, put him on the stand. In Virginia the type of felony for which your client was convicted can never be divulged, only the number of such convictions. If your client has a record, tell the jury in voir dire and ask them if the existence of the record would prevent them from believing the testimony of the defendant. The sting of a criminal record is gone and some juror will remind the others of the pledge. Never refuse to put a defendant on the stand because of his record, unless this is a charge for an identical offense as the one for which he has already been convicted. With good voir dire there is no presumption of incredibility because of character.
RULE ELEVEN
NEVER LET A CLIENT THINK THAT HE IS SO SLICK OR GLIB THAT HE CAN LIE AND FOOL TWELVE AVERAGE AMERICAN CITIZENS
Remind your client that if he gets mad or hateful, he will lose. Remind him that he need not fear being tricked on the stand as long as he tells the truth. No examiner can ever trick or beat an honest witness.
If your client has a long history of felony convictions with guilty pleas, he can now tell the jury, "I did all of those, I did not do this". It works.