Answer to Question 1
n conducting an interview, your primary goal is to obtain information. Although some people communicate information readily and effectively, others may need prompting and encouragement. If such people feel comfortable in your presence and in the interviewing environment, they will generally be more willing to disclose information. As you begin, remember that the interviewee may be nervous or uncomfortable. You should put that person at ease as quickly as possible. A minute or two spent chatting casually is time well spent. Also, saying or doing something that shows your concern for the interviewee's physical comfort helps to make the interviewee feel more relaxed. For example, you might offer a cup of coffee or other beverage.
Using language that the interviewee will understand is essential in establishing a good working relationship. If you are interviewing a client with only a grade-school education, for example, do not use the phrase facial lacerations when talking about cuts on the face. If you are interviewing a witness who does not speak English very well, and you are not fluent in the witness's language, have an interpreter present. Because most clients and witnesses are not familiar with legal terminology, avoid using legal terms that will not be clearly understood. If you must use a legal term, be sure that you define the term clearly.
Answer to Question 2
The investigation summary should include an overall summary of the findings, a summary of the facts and information gathered from each source, and the paralegal's general conclusions and recommendations based on the information obtained during the investigation.
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