b. Translating Expert Testimony and Legalese into Plain English. 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. We are a community-supported, non-profit organization and we humbly ask for your support because the careful and accurate recording of our history has never been more important. Counties found in the sub-region include parts of Somervell, Erath, Hamilton, Comanche, Brown, Mills, Bosque, Hill, and McLennan counties. Login (855) 847-0999 calendar@huseby.com In the western counties, where the average size of land tracts increases, cattle ranching is the predominant land use. 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. Texas State Historical Association (TSHA) Discuss different strategies of how to approach this problem with your expert witness, so important parts of testimony are not left out. 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. Cross Timbers oaks are used for firewood, railroad ties, and poles, but the most important function of the timber belt is preserving water. County . Hundreds of e-mails. [7] In southern Oklahoma, the Cross Timbers are located on the very edge of the Great Plains, as they border directly parts of Level I Ecoregion 8.0, the Eastern Temperate Forests; elsewhere, the Cross Timbers are separated slightly from the Eastern Temperate Forests. Fax: 817-272-5977. The objective is to cast significant doubt on the credibility of the expert. Other factors such as fragmentation of once continuous habitat into smaller land holdings, competition for food and cover with livestock, conversion of woodland habitat to improved pastures or other agricultural enterprises, urban and rural developments, and lack of proper wildlife and habitat management also determine the density and diversity of wildlife. . ", In 1840, Col. 26 Downer Avenue Campbelltown SA 5074; 2287 0 obj <>stream Discovery Litigation Services is skilled in Cross Timbers depositions and court reporting. If you change your mind, you can easily unsubscribe. H|OO@)HvBBMla=v=]@=4sIFv["iARDk5O $88][D4,)rs}%(DL`_"_"qw7)Ebh@iOUm Y2+kCunCQI olW 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. Recreational activities near Pinewood Hills Independent Senior Living Apartments are plentiful. Talk with your witness, if truthful and appropriate, about avoiding absolutes. This means making statements like in all cases or every time. This way, the witness does not close to the door to a certain line of questioning and open himself up to impeachment later. Expert witnesses may respond poorly to perceived hostility on cross-examination. If there is a good likelihood the case may be tried, you may want to hold some of your strongest attacks. 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. LOCATION. What Are the Benefits of Having an Estate Plan? Soil and variations parallel both the topography and the geologic materials. Do not let the expert move from a topic if you think it has not been sufficiently addressed. 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. The towns of Sand Springs, Sapulpa, Ada, and Shawnee, Oklahoma fall within this large area; Bartlesville and Okmulgee lie on the eastern edge. 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 expert may provide an even more perfect setup for your next question than your question did. [2] Although local relief is relatively low, it is generally greater than that in the surrounding ecoregions, although this is not the case with the Flint Hills in Kansas.[4]. The most knowledgeable expert in the world will do little to help your case if the judge is asleep. Ecoregion 5 - The Cross Timbers and Prairies. a. Direct link to Levi's post Can acid rain dissolve hu, Posted 6 months ago. 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 any personal information to the agency. Posted 6 months ago. This field is for validation purposes and should be left unchanged. How you ask questions at a deposition depends upon your purpose in that deposition. 1999). 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. 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. Another strategy to handle this type of question is to say in some circumstances if that is the case. Most of this region is underlain by various limestone formations. There are other considerations that will guide your questioning style. Handbook of Texas Online, Some of the areas underlain by deep sands support a growth of tall grasses. See for yourself why so many call us their reporting company. On June 19, 2014, Burger initially filed a Complaint in the United States District Court of the Southern District of Ohio. 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. 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? All rights reserved. The location of the East and West Cross Timbers was well known by these early travelers who used them as points of reference for travel. Numerous U.S. Direct link to lol.lamo.hi.bye's post Rocks are left out in the, Posted 21 days ago. Email subscriber privacy policy I. CPLR 3110 (1) A. The attorneys objective on cross is to weaken the experts testimony and thus will undoubtedly frame yes or no questions in such a way to achieve that purpose. . The region from one river to the other, is no less bountifully supplied with buffalo, bear, deer, antelope, wild boars, partridges, and turkeys. The minute you are arguing with the witness, you are not going to win. The altitude of the belt is slightly higher than that of the surrounding prairies. The Eastern (or Lower) Cross Timbers, a narrow band of blackjack and . Some rules may affect what you are allowed to do on cross examination. The deposition of an expert witness is the culmination of the opposing party's defense or prosecution theory of the case. Military divorces are handled, For many people, the holidays are a time of joy and happiness where the traditional obligations of work and school are put on hold, and, Aspatore Books from Thomson Reuters Westlaw. Nearly all surface rocks of the North Central Texas were deposited during the Cretaceous Period (145-65 millions years ago). 26 Downer Avenue Campbelltown SA 5074; The region is well adapted for truck farming. Sandy loam soils are productive for agricultural crops such as peanuts, small grains, fruit trees, sorghum, pecans, and truck crops. The East Cross Timbers - In Northcentral Texas, the East Cross Timbers vegetative sub-region is a narrow strip of timbered country extending from eastern Cooke County on the Red River south to western Hill County and includes portions of Denton, Tarrant, Johnson, and Hill counties. 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. Eliciting Deposition Testimony: Real-World Application of Techniques. These experts often are minimally credible, because they are unwilling to concede any point, even when the point is beyond dispute. 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. The presettlement Cross Timbers are believed to have covered approximately 28,000 square miles (7,250,000 hectares), extending from central Texas across . Direct link to I am Rhys's post Fjarrgljfur looks like, Posted 2 months ago. See, New Court Rules, infra. The ending is what everyone always takes away. Deny that the document she wrote is a true statement? The greater the familiarity, the greater the acceptance. Often, an expert such as a treating doctor who is not an outright advocate for the other side will concede points when appropriate. You must establish control early by making the expert answer your question. We understand you may have questions about attending depositions in-person during COVID and we can help you tailor your deposition experience to your comfort level. Yes. Exposed sandstone rocks and boulders dominate landscape features in many areas. Cross Timbers Royalty Trust operates as an express trust in the United States. The historical structure of the Cross- Timbers forests in this region has been altered, mainly due to fire exclusion, such that the current . "Acid rain is caused by the release of sulfur dioxide and nitrogen oxides into the atmosphere, where they react with water, oxygen, and other chemicals to become sulfuric and nitric acid respectively. [9][10][12], Coal mining has historically been an important activity, as bituminous coal deposits are found throughout the region;[13] indeed, the town of Newcastle in Young County was named after the English city of the same name due to the coal connection. Direct link to I love Isabelle's post Mechanical weathering is , Posted 6 months ago. That can lead to a lengthy, tedious cross that does not capture the judges attention. Considerable urban growth and expansion throughout this region will continue to impact wildlife habitat resources in the future. To determine whether, if any of the facts as the expert understands them were changed, the expert would change his or her opinions. Indians used the Cross Timbers as a north-south avenue that afforded secrecy from enemies. Mehjabeen Rahman, Preparing an Expert Witness for Testimony A Checklist, The Expert Institute, (January 4, 2016), https://www.theexpertinstitute.com/preparing-expert-witness-trial-testimony//. cross timbers deposition. Soils at the surface, consequently, support the growth of plants adapted to higher alkalinity, such as live oak and juniper. When preparing for cross, every question should be analyzed to see which of those three things are challenged. For example, by allowing them to describe their impressions and reactions as they started going through their damages calculations or as they read the opposing experts report, it allows the judge to understand how the expert formed their final conclusions. Direct link to prehistoric-rishi's post without weathering, erosi, Posted 3 months ago. cross timbers deposition. Land use practices associated with these and other ventures created a landscape that experienced invasion and domination in some areas by problematic brush species such as mesquite, Ashe juniper and other native woody species. The East Cross Timbers - In Northcentral Texas, the East Cross Timbers vegetative sub-region is a narrow strip of timbered country extending from eastern Cooke County on the Red River south to western Hill County and includes portions of Denton, Tarrant, Johnson, and Hill counties. This page was last edited on 17 February 2023, at 08:53. Mr. Burger purchased and installed Decking on his home in the summer of 2010. Q: And that-to use your words-concerned you, isnt that true? Development plans. When an opposing expert is willing to render opinions favorable to your case, do not be afraid to make use of that testimony. Overgrazing by livestock and elimination of naturally occurring fire also reduced native grass cover and allowed the invasion of other less desirable annual grasses and forbs. 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. "[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]. Cross Timbers Royalty Trust (NYSE:CRT) declares $0.161/share monthly dividend, 8% increase from prior dividend of $0.149.Forward yield 9.0%Payable Dec. 14; for shareholders of record Nov. cross timber: [noun] a strip of woodland chiefly of oaks stretching across grassland especially in Texas. Direct link to braalt02's post Yes. Mechanical weathering is the creation of sediment through physical means. This is a skirt of woodlandcalled the Cross Timbers (West Cross Timbers)Whether this was once a beach of a mighty lake or a sea we must leave to the geologist to determine." What Distinguishes a Military Divorce From Other Types of Divorces? In that state, it covers eastern Chautauqua and Elk counties and smaller portions of Greenwood, Woodson, Wilson, and Montgomery counties, while in Oklahoma, this region covers all of Seminole, Pottawatomie, and Okfuskee counties, large parts of Osage, Lincoln, Creek, Oklahoma, Cleveland, Pontotoc, Hughes, McIntosh, and Okmulgee counties, and smaller parts of Logan, Garvin, Murray, Pawnee, Tulsa, Wagoner, and Washington counties. HVpTWg6o@ <6dw#H1Vwl&$ )F((h-BP#P*"m%V 8Nqs~9.hdF8l#h!> 6DLylK]7j#qMDDnPA5 _}hqiKIH|xc-u^4{|W:rI@ .Vo@ *{v"Y1p\"iyR~*v5Jzvc%Sy,">J0z)-W(Q\XXP*Q33K4tay|$B1R*0LZqi)S%BQ]tQ?u\.F0 )wTDFG'QO-pmlI4-S,\9,D# ZXuiB3C514q$hDl}4;Z2+9>g@V $!xt El-![OvA6`s*hIa]! Extensive areas are still used for livestock grazing, but climax plant communities have been altered. 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. Good experts have probably spent several times as many hours on cross in a courtroom as you have. Our court reporters, videographers, and team members have been educated on Huseby's in-person deposition guidelines. 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. In most jurisdictions, re-direct is limited to matters that were covered on cross. Much of the sub-region contains habitat that supports populations of white-tailed deer and other wildlife species. Beyond that, with respect to each opinion the expert has, make sure you ask the expert to exhaustively identify all the bases for each. hb```e``c`230 P9CLlll?9qZHx*"9p1qrxqmG\B/_8:x89vsp\==c/vq\\wUz2Ev={mnmwoIxv;D@YY .l @dp&0f X;"@ For example, a stream can dislodge soil particles from its banks. 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. The other party only gets to cross examine the witness. Thousands of e-mails. If a question is difficult to answer by simply stating yes or no, let your witness know it is perfectly fine to tell the questioning attorney that such a simple answer cannot be provided in that context. Washington Irving, in 1835, described it as "like struggling through forests of cast iron. [4] The Cross Timbers are contained within the WWF central forest-grasslands transition ecoregion. This can only be accomplished by addressing the credentials, assumptions and opinions that the expert has testified to that you know you can demonstrate are not worthy of the jurys belief. Fjarrgljfur looks like a really cool place to go camping. In Texas, this area includes the towns of Weatherford and Mineral Wells; Stephenville lies on the eastern fringe, while Brownwood is on the western edge. you may want to treat the deposition as a cross-examination . Language links are at the top of the page across from the title. A: Yes. [2], An extension in two branches of the Cross Timbers into southwestern Oklahoma, this area features reduced tree density and height, but also small forests dominated by sugar maple, bur oak, and live oak in deeper river canyons. Much of the land in this region is also used for livestock ranching for cattle, sheep, and goats. Considerable farming and livestock grazing operations were initiated by early settlers in areas of sufficient soil depth in this sub-region. 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. The most tornado-prone ecoregions in Texas are the Rolling Plains, the Cross-Timbers and Prairies, and the Blackland Prairies. 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. E-Newsletter Archive. Kara M. Burgos, Andrew B Hebl, & Eric J. Ryberg, 101: Deposition Techniques: Get Your Ducks in a Row, Wisconsin Lawyer, (September 1, 2013), http://www.wisbar.org/newspublications/wisconsinlawyer/pages/article.aspx?Volume=86&Issue=7&ArticleID=11015/. Elicit all the experts opinions and bases of opinions. It was also a formidable obstacle to travelers because of the density of growth. Direct link to Mark's post Acid rain is about 100 ti, Posted 2 months ago. al. This was an important influence on early settlement as underground water was available from shallow wells dug into the Trinity sands. 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. Among the Pennsylvanian outcrops occur scattered exposures of hard limestones; without exception, such exposures are characterized by a typical savanna landscape, comprising scattered mesquite shrubs underlain by a floor of sod-forming short grasses. Children under 13 years of age must have a parent/guardian's consent before providing
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