( Refer to the general instructions
for the full discussion of how to use this specific section of the litigation
Prepare one Witness Summary form for each one of our witnesses. Fill in the
name and contact information. Place the Witness Summary forms behind the
Our Witnesses tab. Put the forms in alphabetical order.
Unless you have been instructed to do so, let the attorney prepare the rest
of the witness summary form, either by handwriting or dictating what is to be
typed on the form.
File behind the Witness Summary form, for each witness, the miscellaneous
materials which are helpful in handling the witness, such as copies of
statements, copies of the attorney's notes of interviews or miscellaneous
facts, diagrams or notes about what others have to - anything that can be
helpfully used in examination of the witness.
Behind the included "Witness Summary" form in this kit, you will find a
form titled "What other witnesses are there?". Give that page to our client.
Ask the client to make notes and return it to you. It is important to see if
they know someone you have not asked or thought about. It is also impressive
to the client if you give them some form of homework that recognizes their
ability to contribute to the case.
Attorneys --- read the following instructions in this
box. You can do the following yourself, or you can instruct your legal assistant or
secretary as appropriate to our situation.
Witness Summary sheet has a section "What the witness can prove".
Notes should be made here, listing, in summary form, the items this
witness can say. Write these items down under the line for "What Can
Witness Prove." Quite frequently, this listing of expected testimony
will need to be revised prior to the trial, but this is the basic
place to list the crucial items that the witness can provide.
Remember, this is only a summary of the essential points.
□ The form
has a space to indicate the personal characteristics of that witness.
When a deposition is taken of the witness, or the witness is
interviewed, the attorney should make notes, on the form provided, as
to the appearance and demeanor of the witness. This information helps
in determining the method of handling that particular witness.