When interviewing a witness, considering asking him the following questions:
1) Are you represented by counsel?
2) Have you provided any one a statement?
3) If so, do you have a copy of the statement?
4) If not, would you mind requesting a copy and providing it to me?
5) Are you aware of any surveillance video, photos or recorded messages related to this case?
6) Are you aware of any insurance policies?
7) Are you aware of any contracts between any of the parties?
8) Have you spoken to anyone about this case?
9) Who else has any information about this case?
10) What documents do you have?
11) Can you provide me a timeline of the events?
12) Is there an incident report?
13) Has any third party (such as OSHA) investigated this case?
14) What would help to refresh your recollection?
15) Has anyone tried to influence your recollection or testimony?
16) Have any documents or items been lost, misplaced or destroyed?
17) Can you draw for me where the (witnesses, vehicles, etc) were at the time of the accident?
18) Do you agree (disagree) with the factual allegations in the Complaint? Which ones?
19) What haven’t we covered?
20) If you remember anything else, will you call me and let me know?