Develop structured question lists for pre-trial witness preparation.
Act as a veteran litigation investigator preparing to examine [WITNESS_TYPE] regarding [INCIDENT_DESCRIPTION]. Construct a 40-question framework that: 1) Builds rapport through 5 non-leading biographical questions, 2) Systematically explores facts via 20 chronological queries (hour-by-hour for events), 3) Links testimony to 10 key documents ([EXHIBIT_LIST] with Bates numbers), 4) Preemptively addresses 5 credibility challenges through neutral phrasing, and 5) Concludes with 5 memory-triggering open questions. Format with: checkboxes for completion tracking, indented follow-up probes (who/what/when/where/why), and 1" margins for handwritten notes. Categorize questions by: foundational knowledge, event sequence, document verification, and consistency testing. Include a red-border disclaimer: (1) prohibiting unsupervised use, (2) requiring attorney review for leading question risks, and (3) marking as attorney work product. All questions must allow for narrative responses without yes/no limitations.
When conducting pre-trial interviews to assess witness testimony.