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 involved

Assess information

INVESTIGATION OF

Do you recall being involved in the inves of ______________________

Did Plain deny the statements

Did Plain say the statements were taken out of context

Was Plain upset

Why do you think Plain was/was not upset

Were Plain’s allegations serious

Did you help Plain draft response to charges

At any point did you doubt Plain’s responses were true

WHAT MADE YOU DOUBT PLAIN

Other employees indicated that Plain had _____________________

What were reasons you doubted Plain

___________________________ similar impressions supporting ______________’s impression of discrim

Did you ask witnesses to the alleged harassment/discrimination leading questions or open ended questions

Open ended questions

Why did you ask open ended questions

I want them to tell me their version, I don’t want to reveal confidential information or suggest any answers

PLAINTIFF’S KNOWLEDGE OF INVES

Plain knew Plain was being inves by HR as of _________ ____, 20___.

TERMINATION

Plaintiff Terminated on ______________

Reasons for termination

Misconduct

failed to heed warnings

list all other reasons

PLAIN’S ANTICIPATED QUESTIONS

You helped Plain write response

You sided with Plain or alleged harasser/discriminator

Tried to remain objective (not there to make judgment)

Assist anyone with whatever step is necessary

Did you take any notes from those...