Maintaining a resolve and not being overcome by emotions or getting flustered under pressure is the most important part of an experts mindset when on the stand. If the witness will be available at trial, your purpose more likely will be to elicit the witnesss story. The deposition of an expert witness is the culmination of the opposing party's defense or prosecution theory of the case. Instead, it might be better to use a pure discovery deposition to pin down what a witnesss story will be without revealing your best documents. Parks and Recreation. Much of the sub-region contains habitat that supports populations of white-tailed deer and other wildlife species. When only one party serves the notice, that party gets to depose the witness as direct examination. Fort Worth Prairie - In Northcentral Texas, the Fort Worth Prairie vegetative sub-region is located between the East and West Cross Timbers sub-regions, extending from western Cooke and eastern Montague counties on the north, southward to northern Edwards Plateau and includes portions of Denton, Wise, Tarrant, Parker, Johnson, and Hood counties. Throughout its current range, the Cross Timbers forest ecosystem is vulnerable to land-use change. Part of the difference in the Cross Timbers region and the surrounding regions west (drier) and east (wetter) has to do with the dry line which separates humid air from the Gulf of Mexico from the dry air of the Llano Estacado, the Texas Panhandle, and the High Plains. A: Yes. It can be further subdivided into four ecological or vegetative sub-regions: East Cross Timbers, Fort Worth Prairie, Lampasas Cut Plain, and West Cross Timbers. Crow Holdings has submitted to the town of Flower Mound a site plan proposal for the Cross Timbers Business Park, a 10-building warehouse park in the northwest corner of FM 1171 and Hwy 377. 2272 0 obj <>/Filter/FlateDecode/ID[]/Index[2261 27]/Info 2260 0 R/Length 69/Prev 462257/Root 2262 0 R/Size 2288/Type/XRef/W[1 2 1]>>stream Beyond discovering what happened, be clear on what two or three points you want to establish through a witnesss testimony. endstream endobj 2267 0 obj <>stream [8] Among the few major roads that cross the Limestone Cut Plains are US 281 north to south and US 84 east to west. If you find yourself getting upset or emotional, it probably means that you know you are losing the debate, and it may mean it is time to think about stopping. Home; Projects. Historically, settlers traversing Oklahoma and Texas for points west found the Cross Timbers a thick, vexing place, rough country of woodland thickets and impenetrable vegetation. Sometimes, based on a desire to please the attorney and the court, experts may get ushered into answering a line of questioning outside the scope of their expertise. hVmoH+tw Lastly, your plan for the experts deposition may include hypothetical questions, containing facts and assumptions which you can prove at trial, that will undermine the experts opinions and ultimately win your case. The Western (or Upper) Cross Timbers comprises an irregularly bounded wooded region in north central Texas, extending in a generally southward direction through Montague, Wise, Jack, Parker, Hood, Erath, and Comanche counties. Eliciting Deposition Testimony: Real-World Application of Techniques. [4] The Cross Timbers are contained within the WWF central forest-grasslands transition ecoregion. The Be Brief rule is hard to comply with if the same subject is covered several times. [2][8], The part of this region north of I-20 is sometimes colloquially referred to as the Palo Pinto Mountains;[9][10][11] the hills are isolated, rugged, and scenic, with spectacular bluffs along the Brazos River as it flows through the region. For example: Q: And when you wrote that I cannot justify paying so much for senior staff when we are missing our budget, you believed that to be a true statement, didnt you? c. Effective Use of Evidence/Documents in Examination. Washington Irving, in 1835, described it as "like struggling through forests of cast iron. Reveal number. In Cross Timbers, we will need to find a location to host your deposition. In many instances, opposing counsel may cut off your expert in the middle of an answer, especially if the answer isnt favorable to their story of the case. According to the University of Arkansas Tree Ring Laboratory, the Cross Timbers contain millions of 200- to 400-year-old post oaks, trees predating the birth of our nation and which had already lived for a century or more at the time of Washington Irving's visit to Indian Territory. A broader, southern extension of the Grand Prairie, found only in Texas; it is underlain by limestone rather than sandstone, and serves as a physiological and vegetational transition to the Edwards Plateau, which it borders to the south. Two fragments adjacent to See additional disclaimers, MISSOURI, ILLINOIS, KANSAS, OKLAHOMA, & NEBRASKA FAMILY LAW ATTORNEYS, Charitable Giving and Community Involvement. You may learn the expert considers your experts work to be authoritative, or that the expert considers a treatise in which your expert is published to be authoritative. Thus, its always advisable to simply tell experts to tell the truth. Direct link to salli's post "Acid rain is caused by t, Posted 7 months ago. They have a great selection of Texas wines that run the gamut from sweet to dry and whit to red. The greater the familiarity, the greater the acceptance. Second, within that framework, determine what you hope to accomplish through the deposition. Most of this region is underlain by various limestone formations. 10. The rich loam soils now support agricultural croplands that produce cotton, corn, oats, wheat, sorghum, milo, and other crops. S. Fort Worth, Texas 76118. Preparation includes distilling the key points and determining how to convey them. You must be clear about the purpose of your deposition. V. CPLR 3113 [c] examination and cross-examination of deponents shall proceed as permitted in the trial of the actions in open court A. II. Direct link to Mahiro's post I have a river in my back, Posted 2 months ago. However, in some instances, there can be a concern that opposing counsel may inquire as to what you talked to the expert about prior to trial. Discovery Litigation Services is skilled in Cross Timbers depositions and court reporting. To log in and use all the features of Khan Academy, please enable JavaScript in your browser. The average width of the Eastern Cross Timbers does not exceed fifteen miles, and its features disappear near the Brazos at Waco. Direct link to I am Rhys's post Fjarrgljfur looks like, Posted 2 months ago. al. Failing to listen to the answers you are getting is the next most common pitfall. Direct link to lol.lamo.hi.bye's post Rocks are left out in the, Posted 21 days ago. These experts may be susceptible to being put into a box for purposes of cross-examination. Many woodland areas in this region have been cleared for tame-grass pastures, croplands, horse and cattle ranches, and urban and rural developments, including portions of the cities of Denton, Dallas, Fort Worth, and other expanding inter-city and rural communities. hb```e``c`230 P9CLlll?9qZHx*"9p1qrxqmG\B/_8:x89vsp\==c/vq\\wUz2Ev={mnmwoIxv;D@YY .l @dp&0f X;"@ Best Winery In Grapevine. Exposed flat topped buttes and escarpments capped by Edwards limestone which have been eroded over most of the region. The other party only gets to cross examine the witness. The towns of Duncan, Oklahoma and Walters, Oklahoma, lie in this region.[2]. If you have deposed an opposing expert based on a thoroughly prepared outline and strategy, then you should leave the deposition knowing how you will deal with the expert at the time of trial. Schedule your Cross Timbers deposition today! His remaining testimony is not credible because common sense tells you the document represented what was true at the time it was written. Either by nature or by circumstance, some witnesses will not remember important details, or claim not to remember important details. For the city in Hickory County, Missouri, see, The outline of the Cross Timbers as defined by the, Plummer, R., Narrative of the Capture and Subsequent Sufferings of Mrs. Rachel Plummer, 1839. Our court reporters, videographers, and team members have been educated on Huseby's in-person deposition guidelines. Posted on Nov 14, 2016. Direct link to braalt02's post Yes. cross timber: [noun] a strip of woodland chiefly of oaks stretching across grassland especially in Texas. Texas State Historical Association (TSHA). Richard Gabriel, Redefining Credibility: Turning Expert Witnesses into Teachers, The Jury Expert, (May 1, 2009), http://www.thejuryexpert.com/2009/05/redefining-credibility-turning-expert-witnesses-into-teachers/. No towns of any size lie within this area, although Possum Kingdom Lake and State Park do;[8] the region is crossed by US 180 and Texas State Highway 16. A: Yes. Numerous U.S. Remember the cardinal rule of cross examining and ask only short and simple factual statements. Considering all of these goals will frame whether your questioning style will be primarily like a direct examination, a cross-examination, or a combination of the two. Do not let the expert move from a topic if you think it has not been sufficiently addressed. Every penny counts! The region from one river to the other, is no less bountifully supplied with buffalo, bear, deer, antelope, wild boars, partridges, and turkeys. The city of Arlington, Texas lies within this zone, and Denton and Cleburne are on its eastern edge. Content of this site copyright Texas Parks and Wildlife Department unless otherwise noted. Discuss different strategies of how to approach this problem with your expert witness, so important parts of testimony are not left out. This happens through weathering, erosion, and deposition. The easiest way to control a witness is through the use of exhibits. This way, you are not misleading the court by answering yes or no if the answer truly is sometimes. This paints a better picture for your expert as a credible witness and also weakens opposing counsels line of questioning. It will be easy to get angry and frustrated with an evasive, non-responsive witness. The Ellsworth expedition, accompanied by Washington Irving, entered the cross timbers in 1832; later he wrote, " It was like struggling through forests of cast iron." Mark A. Neubauer, Mastering the Blind Cross-Examination, ABA Litigation, Volume 35, Number 2, (Winter 2009), https://apps.americanbar.org/litigation/litigationnews/trial_skills/tips-blind-cross-examination.html/. By walking the judge through a point-by-point re-enactment of the experts methodology, it allows the judge to see what the expert is seeing as they are analyzing the subject matter. Q: When you wrote in that e-mail you were concerned about meeting the production deadline under the contract, that was a true statement when you wrote it, was it not? There are extensive regions of grasslands and valleys with higher, narrow, often wooded mesa-like divides. [2][4], In Oklahoma, this belt of woodland covers all of Marshall County and parts of Love, Carter, Johnston, and Bryan counties, but in Texas, this region exists as a long, very narrow strip of dense forest stretching from the Red River to just north of Waco, Texas. water can melt/dissolve/break down paper, water can erode rock, and water can also rust/mildly erode scissors(plus the fact that scissors can't cut water, and the fact that paper can't catch water either) so, I guess you could. H|OO@)HvBBMla=v=]@=4sIFv["iARDk5O $88][D4,)rs}%(DL`_"_"qw7)Ebh@iOUm Y2+kCunCQI olW Wildlife management in the East Cross Timbers will prove to be challenging to landowners and will require innovative approaches to management of the habitat resources found there. The term Cross Timbers, also known as Ecoregion 29, Central Oklahoma/Texas Plains, is used to describe a strip of land in the United States that runs from southeastern Kansas across Central Oklahoma to Central Texas. The region at large, underlain by nonlimy geologic materials, is not easily eroded; constructional areas are few, and where they do occur, at the foot of longer slopes, they are of small extent. Managing the Holidays After a Divorce With Children. These landscape changes will have long lasting consequences for wildlife and habitat resources in this sub-region. Historical records indicate much of this region existed as a grassland or open live oak savannah that supported herds of bison and other herbivores dependent on the tall grasses that dominated the region. |-!U`&w. Kjj(-(pJ|wRrAG NA{A$3HL1Q8%_ In fact, outcrops of the Paluxy sands are interspersed among calcareous materials to the east of the Trinity sands; without exception, the narrow belts of Paluxy sand outcrops support a growth of hardwoods, forming ribbons of woodland in an area where grasses would normally predominate. Website and Maintenance by Appeal Design, Court Reporting Cross Timbers, Missouri 65634. The Cross Timbers are a complex mosaic of upland forest, savanna, and glade that form the broad ecotone between the eastern deciduous forests and the grasslands of the southern Great Plains. Judges will retain information better when they interact with that information. Q: You knew there had been a delay in the manufacturing process, didnt you? Indians used the Cross Timbers as a north-south avenue that afforded secrecy from enemies. In the Fort Worth Prairie and Lampasas Cut Plain, shallow soils were formed over Cretaceous limestone parent materials. The areas of ancient Cross Timbers still remaining are some of the last virgin North American hardwood forests. Austin: University of Texas Press, United States Environmental Protection Agency, "Ecological Regions of North America Level I", "Ecological Regions of North America Level I-II", "Descriptions of the Level IV Ecoregions of Texas", "TPWD: An Analysis of Texas Waterways (PWD RP T-3200 1047) Brazos River", "Brazos River Canyonlands The Brazos River", Texas counties map showing the ecoregion; similar to the above map. Rainfall is highly variable in this region, averaging about 25 inches in the western reaches to 35 inches in the east. The Trinity sands area at the east is a plain much of the surface of which is now so eroded as to forbid its use agriculturally. These experts often are minimally credible, because they are unwilling to concede any point, even when the point is beyond dispute. This way, it makes clear that your witness is not evading a difficult question, but is rather answering in the most accurate way possible. Also, when it comes to the judges perception, you want to continue to make sure you are the one who looks credible and forthcoming. and cookie statement. hbbd``b`^$@$b8`v @"#"O This is significant, since bias is a valid grounds for disqualifying an expert witness. About CRT. In May of 1854, J. Pope's report on the exploration of the region for a route for the Pacific Railroad stated ".but by far the richest and most beautiful district of country I have ever seen, in Texas or elsewhere, is that watered by the Trinity and its tributaries. Lampasas Cut Plain - In Northcentral Texas, the Lampasas Cut Plain vegetative sub-region lies south and southwest of the East and West Cross Timbers and Fort Worth Prairie, extending to the upper reaches of the Edwards Plateau. Winter agricultural forage crops such as wheat and oats are commonly planted. You may be able to find information in the treatise or from one of the authors that contradicts the experts opinions. A: Yes. why does acid rain dissolve rocks but not us humans? The natural vegetation is a woodland predominantly made up of dwarfed post oaks. Asking a question more than once is frequently the mistake that destroys much of the impact of the experts first great answer, before he had the opportunity to consider how to better position that answer. This page was last edited on 17 February 2023, at 08:53. This means that when opposing counsel asks your witness is that everything, it is crucial that your witness provides a flexible answer, such as that is all I can recall at the moment. Failure to do so may be grounds for impeaching your witness, or at the very least looks somewhat conflicting to the jury. The woodland and savanna portions of the Cross Timbers are mainly post oak and blackjack oak on coarse, sandy soils;[4] fire suppression in recent years has increased forest density and allowed eastern redcedar to invade as well. The Lampasas Cut Plain is more rugged than the Fort Worth Prairie, being bisected by numerous low buttes and mesas formed by extensive erosion during it geologic formation. Cross Examination Rules, Strategies and Traps to Avoid. The timber prevents rain water from immediately running off the surface and causes much of it to soak into sand that supplies artesian water for hundreds of wells to the east and south of the Cross Timbers. Cross Timbers Royalty Trust (CRT) is a micro-cap, and a tiny one at thatit has a market capitalization of just $145 million. If you doubt that, go back and look over the last cross examinations you have handled. Comanches raided east of the Cross Timbers in the early years, and the Wichitas and others used the wood in the Cross Timbers. In other areas, limestone surface formations and shallow clay soils support grasslands and vegetative plant communities adapted to higher alkalinity. Our skilled team makes sure we supply the correct court reporter in Cross Timbers for your case. Is Alternative Dispute Resolution Right for You? What Distinguishes a Military Divorce From Other Types of Divorces? This allows you to bolster your experts credibility through the opposing expert. Hundreds of e-mails. endstream endobj 2262 0 obj <>/OCGs[2274 0 R]>>/Pages 2246 0 R/StructTreeRoot 450 0 R/Type/Catalog>> endobj 2263 0 obj <>/Font<>/ProcSet[/PDF/Text]/XObject<>>>/Rotate 0/Type/Page>> endobj 2264 0 obj <>stream You must establish control early by making the expert answer your question. About 17 million acres are represented by this region of alternating bands of wooded habitat scattered throughout a mostly prairie region. The true value of depositions may be for impeachment purposes. If the expert refuses to answer a question, establish that on the record to set up a potential motion to strike the expert as a witness. Obviously, helpful opinions given by an opposing expert will be more valuable than if those opinions are coming from your own expert. People spontaneously write e-mails without hesitation and, more importantly, without reflection or thinking. Direct link to 54225's post So basically if I added w, Posted 21 days ago. You should use these concessions to the extent possible to support your case. Put the expert into a box. If you are careful about using leading questions, you will substantially limit the likelihood of the expert being able to successfully say that he needs to explain. Test each question in your outline by asking, can you successfully cut the expert off to a yes or no? The towns of Sand Springs, Sapulpa, Ada, and Shawnee, Oklahoma fall within this large area; Bartlesville and Okmulgee lie on the eastern edge. The altitude of the belt is slightly higher than that of the surrounding prairies. Cross Timbers, Cross Timbers' acquisition strategy has given it a sizeable portfolio of drilling prospects. Remind your witness that the objective of a cross-examination is not to pick a fight with the attorney, but an opportunity for the witness to stick to their guns and present an even stronger case to the jury for your client. A fairly narrow strip dividing the Eastern and Western Cross Timbers, the Grand Prairie differs in physiography, topography, and land use from both of these, as it is much more nearly level and better suited to agriculture. If the last area of questioning finishes off the experts credibility, you have one. Direct examination is your chance to paint the picture of your case to the judge, and when concerning an expert, the best chance to present your witness testimony. Office: 817-272-5978. Having a plan of attack is key, especially with respect to the more highly technical aspects of your experts testimony. [3], Geologically speaking, the Cross Timbers are underlain by Pennsylvanian and Cretaceous-era sandstone and limestone that has been moderately dissected, giving the region a gently to moderately rolling topography,[3][4] including some cuestas. It served as a dividing line between the hunting grounds of the Plains Indians and East Texas Indians. Soils of the East and West Cross Timbers were developed on sandy Cretaceous Woodbine and Trinity strata. account_circle Discover the #1 platform to conduct a deposition from the comfort of your home or office, providing you a first-class virtual deposition experience and live support from Huseby techs. Ask anticipated cross-examination questions. For example, instruct your witness that if there is some important portion of testimony that needs to be included, then the witness should take the liberty of saying what needs to be said. The proposed buildings would total nearly 3.3 . See, New Court Rules, infra. Other associated woody species include shin oak, Spanish oak, live oak, Texas ash, mesquite, osage orange, Ashe juniper, eastern red cedar, cedar elm, skunkbush sumac, elbowbush, lotebush, tasajillo, rough-leafed dogwood, flame-leaf sumac, hawthorn, and hackberry. Early travelers through north Texas coined the name "Cross Timbers" by their repeated crossings of these timbered areas that proved to be a barrier to their travel on the open prairies to the east and west. Cross Timbers Royalty Trust operates as an express trust in the United States. Made up of a mix of prairie, savanna, and woodland, it forms part of the boundary between the more heavily forested eastern country and the almost treeless Great Plains, and also . Be sure to discuss with your expert instances where I dont know is NOT an acceptable answer, such as when the question directly relates to a basis or methodology of your experts opinion. All of Hamilton and Coryell counties, large parts of Bell, Lampasas, Mills, Erath, and Bosque counties, and smaller parts of Williamson, Burnet, Brown, Comanche, Hood, Somervell, and McClennan counties, including the towns of Killeen, Copperas Cove, and Lampasas as well as the Fort Hood Army base, fall within this region. Manage My Subscriptions, archive The term Cross Timbers, also known as Ecoregion 29, Central Oklahoma/Texas Plains, is used to describe a strip of land in the United States that runs from southeastern Kansas across Central Oklahoma to Central Texas. 2261 0 obj <> endobj This is a skirt of woodlandcalled the Cross Timbers (West Cross Timbers)Whether this was once a beach of a mighty lake or a sea we must leave to the geologist to determine." The short, stout oaks that grow in the Cross Timbers were not usable as timber, and those that were not cleared for farmland constitute one of the least disturbed forest types in the eastern United States (MADISON), with some 890,000 acres (3,600km2) of old-growth forest scattered throughout the region. Ecoregion 5 - The Cross Timbers and Prairies. %PDF-1.7 % If the experts answers appear to defeat the credibility challenge posed by your questions, then you have lost and the expert has won. Retained experts are notoriously difficult to control, particularly for a new lawyer. When preparing for cross, every question should be analyzed to see which of those three things are challenged. Save that effort for when you have your own expert on the stand and she is willing to cooperate in your educational endeavor. If the witness cannot remember key details, you will sometimes have deposition testimony or other extrinsic evidence to rely on, which will be helpful in refreshing the witnesss memory. This is extremely important, since your witness can only make statements that fall within the scope of your witness expertise and any statements made otherwise will be stricken from the record. endstream endobj 2266 0 obj <>stream The Eastern and Western Cross Timbers are formed by a narrow band of woodland extending along Red River. Luckily, there are alternative methods to divorce. *0K7N(s[_/YS!Y ~ZlAiwcxPfyU+u 9pp`9mIyve~6?scv;CP'uS5R,w+cZ}\&Jt"Z5oH]o>%sV\!bEDd.c7|J}4$/ka' W\0Occ= "[17] Josiah Gregg described the Cross Timbers in 1845 as varying in width from five to thirty miles and attributed their denseness to the continual burning of the prairies.[18]. The term "Cross Timbers" refers to an ecological region of woodland and forest vegetation in central and eastern Oklahoma. Post oak-blackjack oak woodlands characterize much of the West Cross Timbers. Every person works hard to collect different property, investments, and assets throughout their life. Take the lead on how to engage the judge. Both ecoregions receive similar amounts of precipitation (20-30 inches), but differ slightly in topography, soil, and elevation. Login (855) 847-0999 calendar@huseby.com The Eastern (or Lower) Cross Timbers, a narrow band of blackjack and post oak, separates the region of Black Prairies on the east from the Grand Prairies on the west. The movement of water can create and modify features on Earths surface. Nice! If you're seeing this message, it means we're having trouble loading external resources on our website. This zone also includes portion of Archer, Clay, Wise, Young, Throckmorton, Shackelford, Jack, Tarrant, Parker, Palo Pinto, Stephens, Callahan, Eastland, Erath, Hood, Somervell, Johnson, Hamilton, Comanche, Mills and Brown counties. Covering a fairly small area in south-central Oklahoma and underlain by a unique mosaic of several different minerals, this region includes the town of Ardmore. If you are using documents, consider marking up the documents or drafting your questions on the documents, this can allow you to do follow-up questioning for each document as you go through the deposition. Often what the expert says in response to a great question will provide the most powerful next question in your cross. (Diggs et. The Cross Timbers of Texas is two long and narrow strips of forest region that extend parallel to each other from Oklahoma southward to Central Texas between the ninety-sixth and ninety-ninth meridians and form a marked contrast to the prairies of the state. One of the best ways to get judges to interact with the experts testimony is to make his or her methodology both easy to understand and easy to use. ", Other historic accounts by early travelers in north and central Texas record a much different Texas landscape in many areas that is difficult for us to imagine today. As you approach the deposition date, if the event cannot go forward, no problem, up to 24 hours (business day) prior to the event you can reschedule or cancel with no penalty. In some jurisdictions, cross is strictly limited to the scope of direct. If the ending is flat, or the expert scores some big points, it is likely that the judge will conclude that the expert won the battle. The company plans to . Posted 6 months ago. Another strategy to handle this type of question is to say in some circumstances if that is the case. Lay them out like a long mosaic and weave them back together as you tell your story through cross-examination. It will almost always be where you allowed the expert to take control of the traffic and begin to explain what she had already carefully explained on direct examination. Anything else will surely land you in hot water-this witness will take advantage of any opportunity to derail your case with his version of what is important for the jury to know.
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