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Recorded Interviews
When Preserving Testimony Matters


The main task a claims investigator has is to ask questions of the involved parties and to document his findings. Aside from asking informal questions of the myriad strangers we meet on the street (in offices, homes, etc.), investigators also have to conduct formal, recorded interviews of those key witnesses we find, who have critical information germane to the case. Ideally, it is best to do this immediately when when we find them, but oftentimes we have to set up an appointment.

In either case, the most common mistake made in taking recorded interviews is failing to plan, where the investigator thinks, “I got this,” when in fact he does not. By failing to plan I mean by not following an outline. I know colleagues who don't think they need to follow an outline, and I have even read articles (from so-called professionals) where the author stresses that he “doesn't need” an outline, almost as as if to somehow “prove” how professional and knowledgeable he is. To our way of thinking, this just proves the opposite: how careless and haphazard the investigator is.

It doesn't matter if an investigator has 15 years' experience taking recorded statements (hey, we've been doing this since 1988), they still need a formal outline to follow. Always. Every time. While it is true each case is unique, and that each interviewer should be free to go off on whatever factual tangent he or she wants, as the interview progresses, there is still a basic structure to every kind of case there is. Over the years, what we have done is develop several different "blueprints" (a separate statement outline for each kind of loss/investigation type—slip and falls, bar fights, auto losses, arson, etc.). A folder with each kind of possible statement goes with us in our investigative gear every time we go out.

It is our conviction that the investigator who develops extensive general outlines (between 8-20 pages apiece), and who will review/amend the basic outlines to fit the reality of each unique case he has, thereby goes out prepared to create the best possible likelihood for getting everything he need for his client on his statements. The true investigative professional uses his outline as a checklist to follow, so he doesn't miss anything, but he has also added additional questions that are unique to his particular case. With these plans in place, there is nothing preventing the investigator from going off on unforseen tangents, as the reality of the statement unfolds in situ, either.

By contrast, the hot-shot who goes into an interview situation, with no notes and no outline, is going to miss key questions. No one is good enough to remember every possible question to ask on-the-fly.

With that said, our firm breaks down statement-taking charges into 3 basic categories: 1)Recorded in English, 2)Recorded with an Interpreter, taken via 3) Written Statement. All of our recorded interviews are meticulously-planned in advance, with basic forms we use for each type of loss, which have been compiled over the years from our own experience. While we follow these as a general framework for the inquiry, before we go out, we also amend and tailor the basic outline to conform to each unique, specific case, inserting key questions which are germane to this particular circumstance. This is all figured into our recorded interview charges. We make our price distinctions based on the following:

  1. Recorded in English: We charge a basic, 1.0 hr flat rate for taking any and all recorded statements in English, where we ask questions and take notes based on the above preparation.

  2. Recorded with an Interpreter: A recorded statement, taken with the assistance of a foreign-speaking interpreter, theoretically takes twice as long to complete as does a conventional interview, due to the back-and-forth translation effort by the hired interpreter. Because of this, we bill all interpreter-assisted interviews at a 1.5 hr flat-rate (additional interpreter fees notwithstanding).

  3. Written Statements: Written statements are usually not advisable, a) because they take much longer to complete than a recorded interview, and b) because you can't possibly cover as much ground with a written statement as you can speaking freely in a conversation. However, written statements sometimes are preferable, usually secured as a brief synopsis of evidence to present to a judge in a small claims court proceeding, etc. We charge actual time for these statements, with or without an interpreter.


J. Koerner Investigations
P.O. Box 4186
San Dimas, CA 91773
Tel: (909) 225-5448
Fax: (909) 267-9760