In grievance and arbitration steps, the union will often bring forth a witness to establish a fact or set of facts. Most grievance officers have a general idea what they want to ask in order to establish those facts.

Not every witness is a good witness. Part of that problem comes from the process itself; n a witnesses' testimony needs to be precise and this puts pressure on them. Also, the situation itself is a stressful one. As a union representative, you need to work with your witness to lessen the stress in order to bring out what the witness knows. Here are some help hints on interviewing witnesses.

1. Speak with witnesses as soon as possible.  Take notes.

2. Know what your witness will say.

3. Inform the witness of questions you will be asking.

4. Tell the witness what to expect during cross-examination. 

5. Tell the witness to admit, IF ASKED, that you have spoken with him or her. Don’t have them lie or hide the fact of a conference. IF ASKED, “What did your union representative tell you to say at the hearing, reply, “He/she told me to tell the truth.”

6. Tell the witness to be brief, non-technical, and not to argue.

7. Plan your questions according to the information your witness has offered.

8. Tell your witness not to be evasive. If they cannot remember or do not know — say so.

9. If witness is sure of fact, use words like “I remember.” Do not have them use language like “I think.”

10. Don’t let witnesses get shaken by cross-examination. Tell them not to get excited, lose their temper, or get careless with an answer.

[back]