You're discovering the perilous process of pro se litigation. The cost of a consultation with a local attorney will likely be relatively small.
Under the rules governing the conduct of attorneys in New York it may be necessary to remind you that this answer could be considered attorney advertising.
Definitely hire a local attorney. Hard to teach law in a shirt time. It is a worthwhile investment to speak to an attorney.
If this answer is helpful, then please mark the helpful button. If this is the best answer, then please indicate it. Thanks. For further information you should see an attorney and discuss the matter completely. If you are in the New York City area, then you can reach me during normal business hours at 718 329 9500 or www.mynewyorkcitylawyer.com.
If your Complaint satisfies the requirements under Virginia law, you MAY be able to turn your Complaint into questions and have your witness anwer yes/no.
My answer is general in nature, please do not rely on it as your sole resource for this very important issue.
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