Employment Defense — Witness Interview Memo
How a defense team turned a fact-witness interview into a privileged memo that flagged both the help and the exposure.
Outcome Snapshot
Full witness-memo workflow. An interview reduced to privileged, strategic work product.
After interviewing a fact witness in an employment-defense matter, the attorney needed more than a transcript. Using Inquisita to test the witness's account against the existing record, the workflow produced a privileged memo that enumerated every favorable point, named the areas of exposure with candor, and closed with concrete strategic follow-up for the trial team.
How it was done — 4-step workflow
Pull the case context
Before drafting, the workflow queried Inquisita for the witness's name and the core interview topics, pulling any prior testimony so the account could be measured against the record.
81 documents cross-referencedSeparate the favorable from the exposure
Every statement supporting the defense was logged and connected to a position, while statements creating risk were flagged by the cause of action they implicated and rated for severity.
6 favorable · 2 concernsCorroborate against the record
Each material point was checked against the documents and prior testimony in the file, confirming where the witness corroborated the defense and noting any contradiction.
Corroboration confirmed in the recordDeliver the privileged memo
The interview was reduced to a four-section memo marked privileged work product on every page, closing with witness-reliability notes and an assignable follow-up list for the trial team.
Privileged memo — strategic follow-up