I once was sitting in a courtroom and one of those lawyers whose billboards appear everywhere sat down to present testimony from a client. He was holding a set color coded, well organized medical records. He presented his client’s testimony about a work-related back injury, and seemed to do well. When Mr. Billboard asked, his client insisted he'd never injured his back before.
The insurance company lawyer looked like a starving mad dog frothing over a fresh steak. With the sadism of a lawyer who can’t believe his good luck, he embarrassed the witness by grilling him about three prior back injuries, including one that was work-related.
The information Mr. Billboard needed about his client's prior history was almost certainly inside the documents he had in his hand. The problem with his client's miserable performance wasn't that he had prior back injuries. The problem was denying he had those injuries, which was the inexcusable fault of Mr. Billboard, the empty suit.