Your supervising attorney is representing Darrel Jones who is suing Bill Johnson for $10,000, for a business debt. They are both sole proprietors.
Darrel Jones claims he sold Bill Johnson 200 widgets in January of 2015 for $20,000 and only $10,000 has been paid, leaving $10,000 owed. Your supervising attorney has told you that Darrel knows this by memory, but has lost his records in a fire and his electronic records were not saved.
Darrel recalls that the widgets were delivered to Bill’s place of business in March, 2015, about the 15th, that they were all satisfactory, and that there were no complaints about them. An invoice was sent with the delivery.
Two payments were made, of $5,000 each, one on June 1, 2015 and one on Nov. 1, 2015. A statement was sent on December 1, 2015, which showed a balance due of $10,000. No dispute of the statement was ever received by Darrel.
These facts need to be verified or corrected. Your side also needs to find out which documents are available from the opposition to prove the case in court.
Darla Dare is a witness and has agreed to meet with you and your supervising attorney about the case. She was a former bookkeeper for Bill Johnson. Bill Johnson and his attorney have no objection to your side interviewing Darla and they have allowed her to review and copy all of Bill Johnson’s business records that show transactions with Darrel Jones.
Using only open ended questions, draft a series of questions that ask for the information about the debt from Darla Dare. Make this paper as short as you can, but make sure you ask for all the information.