(E)  Defendant’s Difficulty in Testifying.  If the defendant does not speak English well, or is unfamiliar with and uncomfortable in the American judicial system, s/he may not make a good defense witness.  If s/he does not testify, the factfinder will likely hold this fact very strongly against the defendant, regardless of the court’s instructions to the contrary.  See Chapter 4, supra.

CRIM DEF - COLLATERAL CONSEQUENCES OF CRIMINAL CASES BIBLIO
American Bar Ass'n Comm'n on Effective Criminal Sanctions & Public Defender Service for the District of Columbia, Internal Exile: Collateral Consequences of Conviction in Federal Laws and Regulations (January 2009), http://www.abane t.org/cecs/internalexile.pdf