Lecture by Mr. Saxton:
There is no standard recipe for examination of witnesses; however, in all cases the starting point is preparation.
Select witnesses who will bring out facts according to your theory of the case.
Start with easy questions.
Dos and don’ts: don’t be wedded to a particular line of questioning; do have an outline of what testimony you want to bring out from each witness; and don’t use more witnesses than are necessary to prove your case.
Lecture by Mr. Sachs:
The employer will go first in a discipline case; anticipate as best you can what Management’s theory of the case will be.
Prepare a trial outline of the case.
Select witnesses on the basis of knowledge; call them in a logical sequence.
Prepare witnesses by letting them know the theory of the case and how they fit in.
When asking questions, do so with simplicity and clarity.
Have a purpose when raising objections.
Never call a witness you haven’t interviewed.