INTERVIEW PRINCIPALS AND WITNESSES

   It is axiomatic in personal injury cases to take statements immediately from the witnesses. There are many reasons for this, some that cannot be confined to paper. Witnesses tend to be sympathetic toward the person you are discussing and an early talk with the witness magnifies his importance and favors your case.

   Witnesses favor employees as against employers, and while most are reluctant to sign statements, they will often make favorable oral statements that the representative may introduce into the hearing through cross-examination, such as "Didn't you state when I interviewed you that the train was going at least 40 miles an hour?" or "Didn't you reply, The railroad policeman caused all of the trouble.'"

   You cannot get the truth of the incident until you get the testimony of all the principals and witnesses: the whole story then becomes the truth. The employee you represent may have told you the truth so far as he knows it; like the three blind men who felt variously of the elephant, you will not find what actually did happen until you fit all the pieces together.

   By interviewing key principals and witnesses before the hearing, you know the entire trend of the testimony. This not only enables you to tighten your defense before you enter the hearing, but to immediately refute during the hearing testimony that is at variance with the facts as you know them.