Open Questions #2 - Follow-up Questions
How to follow-up on the initial answer to get all the information
You should start each sequence of questions with a broad, open question, such as “What happened?” Your witness (client, etc.) may give a long answer. Typically, you will want more information about what the witness just said.
You are best off following up the initial answer with targeted questions starting with any of who, what, when, why, where, how, or please explain…
Note that each is an open question, but by targeting your question, the witness may provide information limited to what you asked. If you asked about the witness’ participation in a meeting, you could follow up the long answer with:
How long did it last?
Who else was present?
Where did it take place?
What notes did you take?
When did the president speak?
Why did you attend?
Please explain your last answer.
What happened after the meeting?
That last question, generically, “what happened next?” is a great segue to the next sequence of questions. When the witness tells you about the next event, you start the process over again with, “Please tell me about it.”
Exercise: using the new technique, interview May Donoghue about her story.
Apply this technique to a case in your own practice or, if in law school, to a court case you are studying.
If you want more detail and exercises, consider The Art of the Interview - How Lawyers Talk with Clients, available from Irwin Law here.