Besides obtaining information from an adverse witness regarding the events which are the subject of the suit, you should also try understand how this witness will attack your claims. Finally, you should attempt to do what you can to turn the witness into a witness for your case. There is certain information you can get from each witness that allows you to attack the witness at trial. Explore lines of questioning designed to elicit the following:
- What information must the witness admit?
- What information shows bias or impeaches the witness’ credibility?
- On what items may the witness’ testimony be limited (didn’t hear or see or experience X, Y, and Z)?
- Where is the witness weak?
- What does the witness know that agrees with your case?
