cross+exam+paula

Name/ Attorney:_ Dylan Rohar __Period: 8___ Case Title: _Thrombold __V__ _OK_ The Witness You Will Question: _Paula Thrombold_ Irving Younger's "Ten Commandments of Cross" 1. Be brief 2. Short Questions, Plain Words 3. Ask Only Leading Questions 4. Never Ask a Question to Which You Do Not Already Know the Answer 5. Listen to the Answer 6. Do Not Quarrel with the Witness 7. Do Not Permit the Witness to Explain 8. Do Not Ask the Witness to Repeat the Testimony He Gave On Direct Examination 9. Avoid One Question Too Many 10. Save the Explanation for Summation * life insurance * chances to leave * door down to the pool
 * Cross Examination **
 * 1)  . What are the main points you want the jury to understand after hearing this witness testify?

How she never told anyone || Told friend about life insurance || Didn’t take chanes to leave || ||  ||   ||   ||   ||   ||   ||  A. credibility B. interest 138-39 “I knew……………………………..life insurance” || 190-191 “I realized…………………………….my clothes” || 176-177 “I think…………………………be normal” || ||  ||   ||  NO  || || Yes 138 ||   ||   ||   ||   ||  Is it true, mrs. Thrombold that you arrived home at 5:40 PM? || YES 182 ||   ||  YES 182 ||   ||  YES 186 ||  189  ||   ||  YES 190 ||  190  ||  191  ||   ||  YES 63 ||   ||   ||   ||   ||   ||  YES 192/195 ||   ||  YES 195 ||   ||  YES 199 ||   ||   ||   ||   ||   ||   ||   ||   ||  What is the information you want the jury to hear last, in order to make a lasting impression? Write a leading question designed to drive home the main thing you want the jury to learn from this witness? ||  ||
 * 1)  Read any other witness statements that discuss interactions with or observations of your witness, to check for any inconsistencies in stories. __done
 * 2)  List all inconsistencies and potential weaknesses in your witness’ story/testimony:
 * 1)  List the two best ways you think you can attack this witness (perception, credibility, memory, bias, prejudice, interest, inconsistencies). Be specific about what aspect of perception, etc.
 * 1)  Does this witness make any statements that are helpful to your side of the case? List them.
 * 1)  Write a list of LEADING questions (seeking only yes or no answers) focused on the first way you intend to attack the witness. In the right-hand column, write the answer you expect the witness to give, with a reference to the page of the trial packet where you found that information.
 * Q&A Statement  ||  Page & Line #  ||
 * Did you ever tell ANYONE, besides your recanted statement, about your beatings?
 * Did you say to bailey cross, “I knew ………life insurance”
 * Q&A Statement ||  Page & Line #  ||
 * At which time, you immediately called the delivery service and the manufacturer correct?
 * You then called Gavin correct? And he sounded drunk?
 * He said to you, “you have no idea how sorry you are going to be” right mrs. Thrombold? ||  YES
 * You thought this meant to expect a beating correct?
 * But you did not leave the house? Even though, as you just said, you were expecting a beating. ||  YES
 * There was decent amount of time before he came home correct? Enough time to even change your clothes? ||  YES
 * Wouldn’t changing your clothes make gavin even madder?
 * 1)  Write a list of LEADING questions (seeking only yes or no answers) focused on the second way you intend to attack the witness. In the right-hand column, write the answer you expect the witness to give, with a reference to the page of the trial packet where you found that information.
 * Q&A Statement  ||  Page & Line #  ||
 * Gavin arrived home at 6:30 correct? And had a glass of wine?
 * Did gavin appear drunk?
 * When he told you to get upstairs you ran straight for the bathroom, locking the door behind you, and to grab gavins gun correct?
 * Introduce exhibit exhibit 1. Can you point out the door to the bathroom? This stairway leads to the pool outside correct? ||  YES  ||
 * You did not take this stairwell and go to help correct? You instead chose to run straight for the gun and load it right? ||   ||
 * When he finally broke through the door, you then shot at him not once but three times. Hit him twice and then killed him. Is this true Mrs. Thrombold ||   ||
 * And this was all before he laid a finger on you. Correct?
 * Q&A Statement  ||  Page & Line #  ||
 * Mrs. Thrombold, you had two chances to get out once gavin threatened you, one when he was still not home, and one when you ran upstairs. But you did not take either of these and instead shot and killed your husband. Is this correct mrs. Thrombold?