Direct Examination Outline: Defendant's H.R. Manager

INTRODUCTION

Name

Where did you grow up

Did you go to high school

Did you attend college

Where did you attend college

How long did you attend college/degree

Did you receive any degrees

WORK EXPERIENCE IN THE HUMAN RESOURCES FIELD

Training in the human sources field

Worked in HR at ____________________

How long did you work there

Approx. ____ yrs

What was your next job

What did you do for _______________________

How long did you work for _______________________

Approx. ___ yrs

What was your next job

WORK AT DEFENDANT

When were you first employed by Defend

What was your job title

Have you rec’d any promotions

How many promotions have you rec’d

____ promotions

What is your current job title

SEMINARS & TRAINING

How many HR seminars have you attended

Do you teach seminars on HR

What kind of seminars do you teach

Maintaining positive workplace

Customer service documentation

Counseling employees

What’s most important in handling human resources issues

Fairness

Do you try to be fair

What have you done to try to be fair

Accurately i.d. issues

Statements from all parties...