CROSS-EXAMINATION involves relatively straightforward skills. Through preparation of your case, and a basic knowledge of the fundamentals of cross, you can set up a winning summation by scoring points during the cross-examination of each witness.

First, know exactly what your purpose is and structure the examination accordingly. Second, always maintain total control of the witness through both attitude and leading questions. Bearing in mind the concepts of primacy and recency, begin either on a high point or in areas where the witness must make important concessions. The less-important and less-dramatic areas should be saved for the middle of the cross, while the ending should also be on a winning point. Potential impeachment materials should be reviewed and used to elicit the answers you require and to impeach the witness by exposing inconsistencies.

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