KEY POINT: FOLLOW-UP QUESTIONS FILMING It is good practice to warn the witness before the interview that, after nearly every answer they provide, you will ask a follow-up question, such as “How do you know this?” or “How do you know whom this happened to?” These followup questions are perhaps the most important questions during the interview, because they prompt the witness to think carefully, to put the story into a chronological sequence, and to provide corroborating information. In short, follow-up questions make the testimony more trustworthy. However, this type of question can make a witness feel you don’t believe them or are questioning their recollection. This is why it’s important to make sure the witness understands, prior to recording, that you are not questioning his or her personal credibility, integrity, or recollection. Instead you are asking because their answers will enhance the value of their testimony. Example: Question: “Tell me what you saw when you first walked into the factory?” Answer: “I saw approximately 100 people working. They all appeared to be under the age of 14. The conditions they were working in were ….” Follow-up question: “Did you say you saw approximately 100 people who all appeared under the age of 14?” Answer: “Yes. That is right.” Follow-up questions: “How did you approximate that number of people?” and “Why do you believe the workers were under the age of 14?” Step 5: Keep Recording Unless the interviewee requests that you stop the camera, try to record continuously. The more continuous the footage, the more reliable it will generally be. If you need to stop recording, it’s helpful to say, “We are going to take a break, and the time is ______.” Then, when you resume filming, it’s helpful to restate the time, date, and location and provide a concise synopsis of the context before starting the interview. Step 6: Interview One Person at a Time Do your best to interview one person at a time, in a place where the interview cannot be overheard, so that the person is more likely to speak honestly and openly, and so that other interviewees are not influenced by their testimony. Step 7: Listen Closely Be a good listener and keep an open mind. Your objective may change as you listen and learn more about what information the interviewee can provide. Be flexible, and based on their answers, adapt your questions as needed. Allow the interviewee to provide an account of the relevant facts in their own words. Do not interrupt them. FOR MORE INFORMATION For an example of what to record prior to an interview, see “Adding Essential Information.” For how to enhance the reliability of your footage through filming techniques, go to “Filming Secure Scenes” at vae. witness.org. 156 VIDEO AS EVIDENCE: FILMING PRELIMINARY INTERVIEWS V 1.0

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