Timing of the interview

  1. Counsel should always interview witnesses as early in the case as possible. Every minute, hour, or day that passes results in a loss of memory, a loss of investigative opportunities, and/or the potential loss of witnesses.
  2. Trial counsel in particular should cultivate a relationship with CID and MPI that provides for a continuous channel of communications, so that trial counsel, without making themselves a witness, can be present as early during (not after) the official investigation as possible.

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