Type of Questions

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.