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You can start questioning your witnesses, one at a time, by asking them their name and asking them some background information, like how they know the parties in the case. You will then have to get into asking questions about the event they witnessed or any other issue they are there to testify about.
Questioning in absolute terms. Words such as always, never, all, only, every, and must should always be avoided, as they don't leave room for doubt. They are either 100% correct or 100% wrong. When you begin questions with Did you always2026 or Haven't you ever2026 you're limiting your witness's options.
At the HearingWhat is the order of events in the courtroom?What do I keep in mind when going to court?Why would I enter evidence in court?What evidence can I show the judge?Does testimony count as evidence?
Cross-examination questions are usually the opposite of direct examination questions. In a direct examination, you have to ask the witness open-ended questions that allow them to fully explain their answer.
As indicated by the term, a leading question is one that leads a witness to an answer, by either suggesting the answer or by substituting the words of the questioning attorney for those of the witness.
Prepare Outlines, Not Scripts. You should also have an outline of what you expect opposing counsel to ask. The operative word is outline. Do not get stuck in a rigid question-and-answer script. At trial, it is important to really listen to the witness' answer and to adapt your questions in real time.
You must ask questions beginning with words such as Who, What, Where, When, Why, How, Describe, Tell, Explain, etc. You should ask questions that allow the witness to provide her own answer. For example, Witness, what did you see at the intersection of A and B streets?
Ask Open-Ended Questions Instead, questions should use simple words and allow the witness to elaborate on various facts. A general rule is all direct examinations should be open-ended, short questions.
At the HearingWhat is the order of events in the courtroom?What do I keep in mind when going to court?Why would I enter evidence in court?What evidence can I show the judge?Does testimony count as evidence?
You must ask questions beginning with words such as Who, What, Where, When, Why, How, Describe, Tell, Explain, etc. You should ask questions that allow the witness to provide her own answer. For example, Witness, what did you see at the intersection of A and B streets?