What evidence is available to the defense?  Witnesses who saw the client at or near the time of arrest must be interviewed and called if they are favorable to your client, as well as any person who picked the client up from custody.

It is critical to take pictures of, and/or videotape the area of arrest to show traffic conditions, the effect of passing traffic, and the condition of the roadway where the field sobriety tests were conducted.

Weather information is available and may be useful if inclement weather may have played a role in your client's arrest.  Rain, snow, wind, heat and cold may go along way in demonstrating for the jury the conditions in which your client was performing tests on the side of the road.

Defense experts to explain field sobriety testing, breath testing and blood tests are imperative to explain the defense side of the case.