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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?
Start by asking the witness their name and address. If your witness is a professional, you should ask what their job is, what their educational degrees are, and how long they have been doing their job. The ask specific questions about what information they have about your case.
Direct examination questions allow a personal injury attorney to ask key witnesses to explain what they saw, heard, or did in relation to an incident. For example, an attorney in a car accident personal injury lawsuit may call a bystander to testify about what they saw just before, during, or after the accident.
So, again, the way to discredit a witness is to bring up prior inconsistent statements that they made. The way to discredit a witness is to call other witness or cross-examine other witnesses and bring up key points about your main witness's testimony and impeach them through over witness statements.
Ask Leading Questions. Unlike questioning of friendly witnesses, you are allowed to ask leading questions of hostile witnesses. A leading question is a question that elicits a "yes" or "no" answer.
Listen carefully to the questions you are asked. If you don't understand the question, have it repeated, then give a thoughtful, considered answer. DO NOT GIVE AN ANSWER WITHOUT THINKING. While answers should not be rushed, neither should there be any unnaturally long delay to a simple question if you know the answer.
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.
Ask Open-Ended Questions A general rule is all direct examinations should be open-ended, short questions. To entice a detailed response, questions should begin with: Who, Why, What, Where, and When.