endstream endobj 2267 0 obj <>stream These landscape changes will have long lasting consequences for wildlife and habitat resources in this sub-region. Owing to the fact that the parent materials are prevailingly noncalcareous, both the soils and the natural vegetation of the Western Cross Timbers areas differ sharply from soils of adjacent areas underlain by either "hard" or "soft" formations that are also highly calcareous. Home; Projects. Discovery Litigation will cover your Cross Timbers deposition. If the witness says, No, I do not believe my statement was true when I wrote it, then he is admitting he is a liar. 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. Robert Neighbors and Rip Ford reached the "Cross Timbers, two parallel strips of timber region that ran down the middle of Texas", in 1849 while blazing an emigrant trail from Austin to El Paso. Soils at the surface, consequently, support the growth of plants adapted to higher alkalinity, such as live oak and juniper. ", without weathering, erosion isn't possible, so I'd say weathering. After the introduction of domestic livestock, farming operations, and control of wildfires, the landscape of much of the Lampasas Cut Plain changed. If there is any significant doubt of who will win the point, leave the question on the cutting room floor. Or perhaps this witness will just be combative-either way, there are ways to control such witnesses effectively. 10. In others, cross is open and can be directed to any subject that is relevant even if not addressed on direct. [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. When you choose us, you dont have to sacrifice quality or service. Best Winery In Grapevine. For example, a stream can dislodge soil particles from its banks. [2][8], A much wider band than the Eastern Cross Timbers, the Western Cross Timbers band extends from far southern Oklahoma, including parts of Love and Carter counties, into central Texas, where it covers large parts of Montague, Young, Jack, Wise, Stephens, Palo Pinto, Parker, Eastland, Erath, Brown, San Saba, and Mills counties, as well as smaller parts of Clay, Cooke, Callahan, Hood, Coleman, and McCulloch counties. Extensive open grasslands and brushy rangelands occur in the West Cross Timbers sub-region. In pioneer days the woodland growth on the Trinity sands supplied fuel for settlers on the western frontier of Texas as well as timber for log houses. [2] It includes a small part of Love County, Oklahoma (the only part of this region outside of Texas) and passes south through western Cooke County, eastern Wise County, and western Denton, Tarrant, and Johnson counties, and also includes parts of Parker, Erath, Hood, Somervell, Hill, and McClennan counties. You get the resources of a large divorce and family law firm AND the attentive service of a local attorney. Underlying layers of limestone slope eastward with the exposed ends of younger layers forming escarpments or "cuestas" that produce the scenic topography typical for the area. If he or she then tries to testify to additional opinions at trial and you had expressly confirmed at the deposition that there were no other such opinions, the additional opinions later offered might be subject to exclusion. 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. This happens through weathering, erosion, and deposition. Q: And that-to use your words-concerned you, isnt that true? The areas of ancient Cross Timbers still remaining are some of the last virgin North American hardwood forests. Cross examining a witness who refuses to be led can be a difficult task. *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= This transference is important because you need them not only to understand your expert but to actually stand in or become the expert in deliberations. (see LOWER PLAINS.). Private message. You may need to object and then move to strike portions of the experts answer. By getting your deposition on calendar now, our Schedulers and Case Managers can work closely with you to adjust or change your attendance options as needed. Copyright 2012 - 2023 Huseby, LLC. Sandy loam soils are productive for agricultural crops such as peanuts, small grains, fruit trees, sorghum, pecans, and truck crops. [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. We have the experience to deliver. Remind your expert of the role that he plays during direct examination and the litigation generally. Note the way to phrase the question-a true statement at the time it was written. Be persistent, but polite. 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. The forgetful witness may be one of the most frequently encountered types of difficult witnesses, and it is important that you learn how to deal with the all-to- frequent testimony of I dont remember, or I cant recall, or That was a long time ago, and I cant say for sure. First, if you are cross examining the witness who doesnt remember, be especially careful to limit your questions as much as possible to elicit only yes or no responses-any place where the witness can add in unnecessary verbiage will likely not be good for your case. Do not let an expert push you around. Remember the cardinal rule of cross examining and ask only short and simple factual statements. Plus, Cross Timbers pays a monthly dividend. 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. That means your side must come across as reasonable and polite. Both ecoregions receive similar amounts of precipitation (20-30 inches), but differ slightly in topography, soil, and elevation. We need your support because we are a non-profit organization that relies upon contributions from our community in order to record and preserve the history of our state. 2261 0 obj <> endobj Extensive areas are still used for livestock grazing, but climax plant communities have been altered. This region was called the Upper Timbers by early travelers due to its higher elevation. Discuss tips with your expert, if appropriate, on how to rephrase some technical explanations and make them easier to understand. %PDF-1.7 % If not, then you can use every piece of ammunition you have and can completely attack the witness and cross-examine on every weak point because that will give you value for settlement. 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. Ask open-ended questions that will allow the expert to elaborate on the most important points of testimony. Texas State Historical Association (TSHA). Signup today for our free newsletter, Especially Texan. The Western Cross Timbers is underlain by three larger groups of geologic formations: the Trinity sands of the Comanchean or Lower Cretaceous, the hard rocks of the various Pennsylvanian formations, and the Continental Red Beds materials of the Wichita formation in the Lower Permian. The objective is to cast significant doubt on the credibility of the expert. Soil and variations parallel both the topography and the geologic materials. [@5`Ol-'CfdzM"%utg'6u%kr)2t&MkW=RwR[OJ;k&M-q^RxUYO}8{H_Q5 o!M+W,/+ukk;rb]{| Cross Timbers APEX Accelerator at The UTA Research institute. The Eastern and Western Cross Timbers are formed by a narrow band of woodland extending along Red River. It was also a formidable obstacle to travelers because of the density of growth. If not, consider whether that question should be dropped or recast. The Cross Timbers are defined by the United States Environmental Protection Agency as Ecoregion 29, a Level III ecoregion. [14], In the mid-to-late 19th century, Comanche Indians occupied this area, and it became a flash point for conflict between various groups of white settlers, the Comanche, and the U.S. Cavalry; Forts Belknap and Richardson were built in the area to protect this part of the frontier.[15]. Our skilled team makes sure we supply the correct court reporter in Cross Timbers for your case. 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. What Distinguishes a Military Divorce From Other Types of Divorces? Toward the south the Eastern Cross Timbers belt spans the ninety-seventh meridian from the Red River to the Brazos River. 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/. Direct link to DRAKEB's post I don't know. When only one party serves the notice, that party gets to depose the witness as direct examination. People spontaneously write e-mails without hesitation and, more importantly, without reflection or thinking. First, do not argue with the witness. If someone is going to argue, it should be the expert. We understand the importance of getting it done right. Mr. Burger purchased and installed Decking on his home in the summer of 2010. The expert may provide an even more perfect setup for your next question than your question did. Direct link to Mahiro's post I have a river in my back, Posted 2 months ago. 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 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. Failing to listen to the answers you are getting is the next most common pitfall. Good experts have probably spent several times as many hours on cross in a courtroom as you have. E-Newsletter Archive. The advent and indeed overuse of e-mails has made cross-examination through the use of documents even simpler, and the use of depositions almost superfluous. Some rules may affect what you are allowed to do on cross examination. 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. Login (855) 847-0999 [email protected] Two fragments adjacent to Much of the land in this region is also used for livestock ranching for cattle, sheep, and goats. You also want to avoid being surprised. 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. The cross of a tough expert should seldom take more than one quarter of the time that was taken on direct. The historical structure of the Cross- Timbers forests in this region has been altered, mainly due to fire exclusion, such that the current . 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? As you are walking the expert through the steps of their methodology, it is also important to ask them about what they were thinking as they looked at the data or results that they were seeing. The most important tip to remind your witness is to stop, breathe and think about the question being asked before providing an answer. If the last area of questioning finishes off the experts credibility, you have one. Save that effort for when you have your own expert on the stand and she is willing to cooperate in your educational endeavor. This happens through weathering, erosion, and deposition. Many trial judges create their own rules of courtroom behavior. 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. First, consider whether the case is likely to proceed to trial. Texas State Historical Association (TSHA) Most of this region is underlain by various limestone formations. The Pennsylvanian outcrops form a plateau dissected by the channels of major streams that have been cut considerably below the surface level. 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. Anonymous, The natural vegetation is a woodland predominantly made up of dwarfed post oaks. Counties found in the sub-region include parts of Somervell, Erath, Hamilton, Comanche, Brown, Mills, Bosque, Hill, and McLennan counties. If the case goes to trial, usually only a very small part of the deposition is ever used. 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. If the witness will be available at trial, your purpose more likely will be to elicit the witnesss story. accessed May 01, 2023, Watersheds of the Red, Colorado, Trinity and Brazos Rivers cross the region from northwest to southeast. %%EOF The Underwood is so matted in many places with grapevines, green-briars, etc., as to form almost impenetrable "roughs," which serve as hiding-places for wild beasts, as well as wild Indians; and would, in savage warfare, prove almost as formidable as the hammocks of Florida. Portions of the Trinity sands area are now important in peanut culture as well as for the growing of small fruits. The soil of the Eastern Cross Timbers differs from that of the Western in that the Eastern is more fertile and therefore produces larger trees and a wider variety of trees and shrubs. 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 easiest way to control a witness is through the use of exhibits. Your questioning style may be open-ended like a direct examination, narrow and controlling like a cross-examination, or a combination of the two. Discovery Litigation Services is skilled in Missouri/court Reporters Cross Timbers/ depositions and court reporting. 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. While looking for the places where you failed to keep the ball in play with only leading questions, look for where the cross fell apart. Direct link to salli's post "Acid rain is caused by t, Posted 7 months ago. You should use these concessions to the extent possible to support your case. Warren E. Platt, Cross Examination of Experts: How to Avoid Hurting You Case, Product Liability Update, (August 26, 2013), http://www.swlaw.com/blog/product-liability-update/2013/08/26/cross-examination-of-experts-how-to-avoid-hurting-your-case/. endstream endobj 2266 0 obj <>stream Fjarrgljfur looks like a really cool place to go camping. The city of Arlington, Texas lies within this zone, and Denton and Cleburne are on its eastern edge. See additional disclaimers, MISSOURI, ILLINOIS, KANSAS, OKLAHOMA, & NEBRASKA FAMILY LAW ATTORNEYS, Charitable Giving and Community Involvement. 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. Ford, J.S., 1963, Rip Ford's Texas. Leasing land for deer hunting is an important economic enterprise of the sub-region. 26 Downer Avenue Campbelltown SA 5074; cross timbers deposition. These experts often are minimally credible, because they are unwilling to concede any point, even when the point is beyond dispute. Email: [email protected]. Dyksterhuis (1948) described the Western Cross Timbers as an area "extending 150 miles south from the northern limits near the Red River, curving westward at the southern extremity. 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. [8] Among the few major roads that cross the Limestone Cut Plains are US 281 north to south and US 84 east to west. The movement of water can create and modify features on Earths surface. No matter how many times an expert has testified at trial, being grilled during cross-examination is always incredibly stressful. Eliciting Deposition Testimony: Real-World Application of Techniques. 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. Every person works hard to collect different property, investments, and assets throughout their life. You may be able to find information in the treatise or from one of the authors that contradicts the experts opinions. What to do when a Witness is Being Evasive of Defiant. 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. 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. Talk with the expert, if truthful and appropriate, about not framing answers in a way to appears partial to one side or the other. About 17 million acres are represented by this region of alternating bands of wooded habitat scattered throughout a mostly prairie region. The soil is thin, sandy, and poorly watered. Feb 2014 Friends. Brainstorm with your expert better ways to present this information that will keep the judge interested in your experts testimony. 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. Terms of Use | Privacy Policy Cross Timbers winery is simply great. This allows you to bolster your experts credibility through the opposing expert. 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. 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. Call Discovery at (855) 847-0999. 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? The most knowledgeable expert in the world will do little to help your case if the judge is asleep.

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