Section 7.5 Checklist (Sample)

• Library: Sources of Proof 2014 Forms

An interview checklist may be a valuable aid in preparing the outline for a particular witness. Any checklist should be used with discretion and prudence. A checklist is not a substitute for an outline tailored to fit a particular witness interview, and it should not be used as one. The contents of a witness’s interview outline will vary depending on whether the investigation deals with an automobile collision, a fire, an airplane crash, or a securities violation. Many valuable checklists, which can be helpful in preparing an individually tailored outline, can be found in Douglas Danner & Larry L. Varn, Pattern Deposition Checklists (4^th ed. 1998 and Supp. 2013?2014).

A checklist for an automobile collision is set forth below:

Interview Checklist (Prepared for claimant, but useful for any witness)

I. Name, age, address, marital status, business address, personal address, phone numbers, and e-mail addresses.

II. Immediately before the accident:

(1) Physical condition of the driver.

(2) Condition of the vehicle (lights, brakes, horn, tires, windshield, steering mechanism, seat belts).

III. The trip:

(1) Names and addresses of all occupants and their location in the vehicle.

(2) Trip history:

A. Point of departure.

B. Destination.

C. The purpose of the trip and for whose benefit the trip was being made.

(3) The precise manner in which the car was titled.

IV...