Chapter 4 – Cross Examination (continued)
- Do not repeat your opponent’s direct examination. Why have the trier of fact hear it again?
- Primacy and recency. As discussed in Chapter two, your first group of questions and last group of questions should be your strongest.
- 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?
- Lead, Lead, Lead. If the answer is that important, lead the witness to it by asking questions that are answered either yes or no.
- Make a statement and have witness agree with it .
- Short concise questions
- Obviously, you want to avoid open ended questions and only ask those ,if the answer is unimportant.
- Keep control of the witness and keep control of yourself.