cross+exam+2

Cross Examination

Name/ Attorney:__dan lynch__ __Period: _8/9__ Case Title: ___state of oklahoma__ __V__ ___paula thrombold___ __The Witness You Will Question:__ _bailey cross_ 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 . What are the main points you want the jury to understand after hearing this witness testify? Read any other witness statements that discuss interactions with or observations of your witness, to check for any inconsistencies in stories. __jkweh__done List all inconsistencies and potential weaknesses in your witness’ story/testimony:
 * she never liked gavin

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. A.hated gavin B. Does this witness make any statements that are helpful to your side of the case? List them. Dan, You're headed in the right direction. use specific quotes from his statement in your questions. 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. yes || 33/ 82 ||
 * Is it true that gavin was the one convincing paula to sell her interest in the business so she could go work for him? <yes (exact quote) || 33/41 ||
 * after paula sold the company, you kept in contact, but not as much correct? <yes (examples include) || 34/90-92 ||
 * and whenever you asked paula if she was ok, she always said she was fine right ? <yes || 34/103 ||
 * when you and paula were talking one day, she told you that if anything ever happened to gavin, she would be ok financially, correct? <yes || 34/113-114 ||
 * and after gavin was killed, you then learned from paula that the insurance policy was worth 2 million dollars correct?

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 # ||

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?
 * Q&A Statement || Page & Line # ||