Chapter 4 – Cross Examination (continued)

  1. Do not repeat your opponent’s direct examination. Why have the trier of fact hear it again?
  2. Primacy and recency. As discussed in Chapter two, your first group of questions and last group of questions should be your strongest.
  3. Have your cross, establish a few strong points. Ask yourself, is this an area that I will want to discuss in closing or is it peripheral?
  4. Lead, Lead, Lead. If the answer is that important, lead the witness to it by asking questions that are answered either yes or no. 
  5. Make a statement and have witness agree with it .
  6. Short concise questions
  7. Obviously, you want to avoid open ended questions and only ask those ,if the answer is unimportant.
  8. Keep control of the witness and keep control of yourself.