- Have a purpose for each question. Too many pro ses and some lawyers ask questions with no clear purpose and that may, allow the witness to reitterate or even strengthen his story, and show there's no convincing rebuttal to certain aspects of his testimony.
- Try to get agreement on the significance of a problem if proven. Assume client says his car stalls periodically, ask the witness if he'll agree that a situation of stalling presents a safety and use problem. If he admits that your case is helped, if he denies it, his credibility is lessened.
- Confirm repairs for a problem Have the witness confirm that the car was presented for repair. Note dealer service people may be honest because the claim is against the manufacturer not their company.
- If there are widespread complaint for a problem, present the material to the witness and try to get him to acknowledge that.
- Confirm bias. Have him acknowledge he has never testified for a consumer, is paid by the manufacturer and is not an impartial witness.
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