Previously, the emphasis was on obtaining information from clients. In this chapter, the emphasis was on preparing witnesses for trial. To properly prepare witnesses for trial, the paralegal needs to have interviewed the witness prior to trial. Preparing for a witness and a client interview are very similar. Make sure you have reviewed the file and understand the case well before setting up the witness interview. You will want to have a list of questions prepared before the witness arrives. Prepare a generic list of questions for a witness to an accident. You will want to use this list as a general guide in preparing real cases and then tailor the guide to those individual cases. To tailor the questions to an individual case, look at any depositions previously taken from the witness. The following are some questions to get you started: ○ What is your full name, and how do you spell it? ○ Have you gone by another name? ○ What is your current address? ○ What was the date of the injury you witnessed? ○ What was the time? ○ Where did the accident take place? ○ How did the injury occur? ○ Did you see any physical injuries to either party? ○ Did you report this injury to anyone? ○ Where there any other witnesses to the injury?