Interviewing - an Overview of Legal Research

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Interviewing the client is a method of collecting information that will be required to enable my attorney to adequately represent the client. As a paralegal, my objective is to help the lawyer collect information about the injury case by conducting client interviews. I must be briefed by my attorney prior to conducting the interview with the client in order to fully understand what the attorney requires from the client in order for the interview to be successful. (Bruno, 2017). Conducting the client interview can take many approaches and among these approaches is the three stage or step model or system. The three step model includes preliminary factual identification, chronological factual overview, and factual development and verification.

Preliminary factual identification

This step will involve asking the client about a general description of the accident or incidence that led to his or her injury. It is also at this stage that I will ask the client the relief that he desires after the case is over. An example of a question to ask in this step would be asking the client to describe his injury, how it came about, and what he or she thinks would like to have done about the situation ("Client Interviewing (1)", 2017). The purpose of this step is to help me summarize my understanding of the case problem.

Chronological factual overview

The chronological factual overview will involve asking the client to provide a detailed step-by-step description of what happened that is the events leading to his injury that ask the client to narrate from the point he believes the problem began, and follow through to the present, step-by-step (Bruno, 2017). It is at this stage that I will probe the client open-ended questions that are non-leading nature for instance "what happened next?" Focus on the client at this stage is paramount therefore the paralegal should not distract the client. Prompt the client with open-ended, non-leading questions like “what happened next?” I will avoid probing for details at this stage ("Client Interviewing (1)", 2017). The purpose of this step is to give the client a sense of control going into the last stage of the interview since he will be focusing on his concerns in the case. This stage also will enable me to obtain full information from the narration of the events as they occurred going into the development and verification of facts about the problem.

Factual development and verification

At this stage and based on the information gathered from steps 1 and 2 I will weigh the facts against what I know to be my attorney’s desires and concerns and other facts that the attorney need to represent the client properly (Bruno, 2017). The purpose of this step is to determine what facts weak or strong, which may be applicable directly to plausible legal claims and those that may require further investigations. This stage also helps pursue questions that could have occurred to me while the client was giving his account of the events leading to the injury. Such questions will reveal greater details for the plausible theories related to the client’s injury ("Client Interviewing (1)", 2017).

Draft five (5) questions that, as a paralegal, you would ask before beginning an interview with a client. Identify the primary purpose of each question.

As a paralegal, I will be careful not to ask a question that may lead to the client repeating himself during the interview. The objective of the first five questions will be to create a connection with the client and to make the client feel appreciated and to as well as getting right the facts about his problem. The following would be my outline of the first five questions I would ask a potential client:

Who referred the client to the firm? The primary purpose of this question would be to acquire insight into the potential client’s sincerity. The question would also help in determining whether taking the case would incur a referral fee.

When did the accident or injury occur? This question will help to find out the status of the case as per the moment the client steps in the attorney's backyard. In most instances, the limitation period may be approaching or even given the time that has elapsed the client might already have compromised his case.

What was the location of the incident leading to injury? The place where the injury to the client occurred is important because it determines the applicable laws. The attorney may not be able to practice where the accident occurred.

What injuries occurred? This question is important since it will enable the attorney to know whether the client can meet the threshold in a motor vehicle accident. The kind of questions here would be diagnostic in nature with the aim of finding out the extent of the injuries and whether the injuries might further progress into even more serious injuries.

Were there any witnesses present? This question is important as it enables the attorney to seize control of an important liability factor. If witnesses were present, the attorney should move forward and obtain information from them as soon as possible.

Develop ten (10) interrogatories, and describe the primary information that you are attempting to elicit from the opposing counsel’s client.

Interrogations help to form a clear and vivid picture of the events leading to the accident. Interrogatories also provide a chance to the opposing counsel’s client to give his account of the incident. To the client's attorney interrogations help him in having a deeper understanding of the events that led to the injury of his client ("Model Interrogatories to Defendant in Car Crash Case", 2017). Some of the interrogatories to be directed to the opposing counsel’s client include:

Provide a precise description based on how the incident took place. This interrogative will involve asking the defendant to give a factual narration of the events leading to the incident that caused injury to the attorney’s client. The purpose is to make the incident more clear and precise.

Please identify all persons known to you to have personal knowledge of the facts regarding the occurrence of the accident. The information sought using this interrogative has to do with the witnesses to the incidence whether eyewitnesses or otherwise. The defendant should also comment on the extent of knowledge that the witnesses have regarding the accident. The witnesses so identified will be used to gather the evidence that will be useful during the trial.

Do you contend that either Plaintiff acted in such a manner as to cause or contribute to his or her personal injuries? This interrogative will aim at drawing out the facts as to why the defendants think that the plaintiff was at fault during the incident. The defendant will be able to demonstrate the manner in which the plaintiff had left himself exposed to the accident.

Please state whether you were under the influence of any drugs or alcohol hours before the occurrence of the accident. The aim here will be to uncover whether at the moment of the accident the defendant was intoxicated which affected his judgment. If he had taken drug or alcohol, the amount and nature, as well as the place he had taken them, should be ascertained for a follow-up investigation

Do you have in your possession any material or items related to the case? The aim of this interrogation is to find out if there are other materials connected to the incident to back up the defendant’s side of the story. Such materials may include photographs of the scene of the accident. Failure to find out such materials may harm the case, especially during the trials when presented as new evidence.

When and where did you receive your driver’s license? This interrogative will aim to find out the experience of the defendants during the moment the accident occurred. The defendant should also provide information as to whether his license faced and restriction to ascertain that he was a driver with good conduct on the road. The place where he obtained his incense should be scrutinized to find out whether he was trained enough before being licensed to drive since poor training is a big factor in contributing to accidents.

Did you take any actions or did you attempt to take any action to avoid the accident? This interrogative aims to gather information about the level of care and due diligence on the part of the driver. If he tried to avoid the accident, he should state in details whether his actions or inactions worsened the situation or made it better. The information he provides will show if the accident could have been avoided or not.

Were there any other person(s) with you in the car when the accident occurred? The defendant’s response to this interrogative will answer the question of the level of the concentration he was in when he was driving. If he had people with him in the car, they might have distracted him leading to the accident

Have you been involved in motor vehicle accidents before in your life? This interrogative will aim to find out the probability and the likelihood of the defendant causing an accident. The case files from the previous accidents can be used to form a strong claim during the trial

Have you and the Plaintiff had any conversation after the accident? The aim of this interrogative is to find out whether the client could have compromised his case without him knowing. The defendant should be asked to provide a factual substance of such a conversation if it ever occurred.

Explain the importance of using interrogatories for a personal injury case. Identify two (2) ways in which your supervising attorney could use the opposing party’s responses to further her case. Provide a rationale for your response.

The use of interrogatories is importance because it helps to identify and gather evidence from non-parties. Interrogatories diversify the means by which to obtain and discover new evidence in a case, such that the attorney does not have to rely on the account of his client alone. Also, through interrogatories, the attorney can make personal observations that add more significance to the evidence gathering process. The significance of interrogatories during evidence gathering makes them be employed in almost every kind of cases by lead attorneys (Statsky, 2008).

There are several ways in which my supervising attorney can apply the opposing party’s responses to further her case including evaluation and observation. The attorney can use evaluation by looking at the new evidence as presented by the defendant which will make him in making conclusions about the case before him. Also by observing the opposing counsel’s client give his testimony, my attorney can use the basic observation techniques to gauge the level of sincerity in the words of the defendants. He can turn the defendant’s bodily reaction against him to solicit the true account of events as they unfolded at the time of the accident which may practically win him the case.


Bruno, C. (2017). Client Interviewing Techniques (1st ed., pp. 9-12). Retrieved from

Client interviewing (1). (2017). Retrieved 6 February 2017, from

Model Interrogatories to Defendant in Car Crash Case. (2017). Retrieved 6 February 2017, from

Statsky, W. P. (2008). Family law. Australia: Delmar Cengage Learning

July 15, 2023
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