Ask open-ended questions that will allow the expert to elaborate on the most important points of testimony. Stiff (Dyksterhuis 1948) who approached the Cross Timbers of Texas from the western prairies stated, "In turning to the northeast, something much resembling an irregular cloud is dimly seen. When you choose us, you dont have to sacrifice quality or service. Much of the sub-region contains habitat that supports populations of white-tailed deer and other wildlife species. [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]. Thousands of e-mails. When an opposing expert is willing to render opinions favorable to your case, do not be afraid to make use of that testimony. This sub-region has a complex geologic history, resulting in a variety of soil types, terrain features, and vegetative plant communities. a. S. Fort Worth, Texas 76118. In addition to not letting an expert push you around, you must be persistent in following through with your line of questions. WHAT DOES AN IN-PERSON DEPOSITION LOOK LIKE? Cross Timbers oaks are used for firewood, railroad ties, and poles, but the most important function of the timber belt is preserving water. Soils at the surface, consequently, support the growth of plants adapted to higher alkalinity, such as live oak and juniper. If the expert continues to offer an evasive non-answer, you must redirect the expert to your question and make him or her answer it. Having a plan of attack is key, especially with respect to the more highly technical aspects of your experts testimony. The Cross Timbers vary in width from five to thirty miles, and entirely cut off the communication betwixt the interior prairies and those of the great plains. The objective is to cast significant doubt on the credibility of the expert. About 17 million acres are represented by this region of alternating bands of wooded habitat scattered throughout a mostly prairie region. Ford, J.S., 1963, Rip Ford's Texas. b. Translating Expert Testimony and Legalese into Plain English. You get the resources of a large divorce and family law firm AND the attentive service of a local attorney. [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. The region has been important chiefly for its mineral resources. Deciding to end your marriage is never simple, especially when you know how difficult the process can be. hbbd``b`^$@$b8`v @"#"O The thick growth formed an almost impenetrable barrier for early American explorers and travelers. Good experts have probably spent several times as many hours on cross in a courtroom as you have. Do not let an expert push you around. Some organizations and maps refer to the Cross Timbers ecoregion as the Central Oklahoma/Texas Plains. Your conduct should always remain respectful. |Kfpss The following, adapted from the Chicago Manual of Style, 15th edition, is the preferred citation for this entry. Children under 13 years of age must have a parent/guardian's consent before providing Signup today for our free newsletter, Especially Texan. Cross Timbers Royalty Trust operates as an express trust in the United States. This region contains the cities of Fort Worth, Granbury and Denton, although Denton lies on the border with the Eastern Cross Timbers. Remember the cardinal rule of cross examining and ask only short and simple factual statements. For example, you may want to wait to use some documents at trial to surprise a witness and not allow him or her time to think of an explanation for a document. 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. Judges will retain information better when they interact with that information. 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. Fax: 817-272-5977. Discovery Litigation Services is skilled in Missouri/court Reporters Cross Timbers/ depositions and court reporting. These landscape changes will have long lasting consequences for wildlife and habitat resources in this sub-region. Language links are at the top of the page across from the title. Deny that the document she wrote is a true statement? 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. People spontaneously write e-mails without hesitation and, more importantly, without reflection or thinking. You can continue to count on us to do our best to serve you with the highest levels of service and support for all of your court reporting needs, whether you choose to continue remotely or move back to in-person across the country. If there is a good likelihood the case may be tried, you may want to hold some of your strongest attacks. Counties found in the sub-region include parts of Somervell, Erath, Hamilton, Comanche, Brown, Mills, Bosque, Hill, and McLennan counties. 200 - 300 year old Post Oaks can be found at: . The natural vegetation is a woodland predominantly made up of dwarfed post oaks. In some jurisdictions, cross is strictly limited to the scope of direct. Hundreds of e-mails. 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. Nice! [19]:116, Coordinates: .mw-parser-output .geo-default,.mw-parser-output .geo-dms,.mw-parser-output .geo-dec{display:inline}.mw-parser-output .geo-nondefault,.mw-parser-output .geo-multi-punct{display:none}.mw-parser-output .longitude,.mw-parser-output .latitude{white-space:nowrap}3400N 9715W / 34.000N 97.250W / 34.000; -97.250. [6] More specifically, the Cross Timbers fall into Level II Ecoregion 9.4, the smaller South Central Semi-Arid Plains. This allows you to bolster your experts credibility through the opposing expert. 1999). How acidic is Acid Rain and how does it happen. [3] Today, land use is a mixture of rangeland, pastures, and farmland. ", without weathering, erosion isn't possible, so I'd say weathering. This ecoregion exists as an enclave within the Western Cross Timbers, stretching from southern Jack County, Texas across northwestern Palo Pinto County into eastern Stephens County, as well as tiny parts of Young and Eastland counties. 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. First, consider whether the case is likely to proceed to trial. Vegetation on the landscape of the Cross Timbers and Prairies Ecological Region of Northcentral Texas has undergone significant changes over the past 150 years. Direct link to Kayla Stout's post Is chemical or mechanical, Posted 5 months ago. These experts may be susceptible to being put into a box for purposes of cross-examination. These experts often are minimally credible, because they are unwilling to concede any point, even when the point is beyond dispute. LOCATION. That means your side must come across as reasonable and polite. Habitat for white-tailed deer, Rio Grande turkey, bobwhite quail, mourning doves, fox squirrels, rabbits and a variety of nongame wildlife species is found here. Consequently, plant communities change dramatically within short distances resulting in different land use potential for livestock grazing, farming, wildlife management, or other uses. [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. The risk of extensive preparation is the tendency to show the judge all that you know. Comanches raided east of the Cross Timbers in the early years, and the Wichitas and others used the wood in the Cross Timbers. 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. Kendall (1841) stated that on July 21, 1841, "We are now fairly within the limits of the Cross TimbersThe immense western prairies are bordered, for hundreds of miles on their eastern side, by a narrow belt of forest land, well known to hunters and trappers under the above name." Some rules may affect what you are allowed to do on cross examination. After the introduction of domestic livestock, farming operations, and control of wildfires, the landscape of much of the Lampasas Cut Plain changed. A party will cross notice a deposition to preserve their right to conduct a deposition on issues of relevance to their position. Soil and variations parallel both the topography and the geologic materials. endstream endobj 2267 0 obj <>stream Also, when it comes to the judges perception, you want to continue to make sure you are the one who looks credible and forthcoming. Since the region has a subhumid climate, its natural vegetation would ordinarily be grass; its scrubby tree growth results from edaphic features. 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. [3] The western suburbs of the Tulsa metropolitan area and the northeastern suburbs of the Oklahoma City metropolitan area also lie within this area. If the last area of questioning finishes off the experts credibility, you have one. County . Texas State Historical Association (TSHA). |-!U`&w. Kjj(-(pJ|wRrAG NA{A$3HL1Q8%_ If the attorney insists on cutting off your witness, instruct your witness to answer the next question by stating the previous question was not completely or accurately answered. https://www.tshaonline.org, https://www.tshaonline.org/handbook/entries/cross-timbers. Direct link to pbro7467's post How acidic is Acid Rain a, Posted 3 months ago. Topographically, much of the Western Cross Timbers is characterized by rough features, in contrast to the smooth outlines of the lands both to the east and to the west. [2] The main highways that cross the region are I-35 and I-35W going north to south (although they tend to skirt the Cross Timbers' eastern fringe south of Fort Worth) and I-40 going east to west. Call Discovery at (855) 847-0999. In our business, there is no margin for error. 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. https://www.tshaonline.org/handbook/entries/cross-timbers. 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. ", Marcy (1866) stated of the Cross Timbers, "At six different points where I have passed through it (Cross Timbers), I have found it characterized by the same peculiarities; the trees, consisting principally of post-oak and blackjack, standing at such intervals that wagons can with out difficulty pass between them in any direction. Yes. Test areas as to which the expert might support your case. You also want to avoid being surprised. 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 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. cross timbers deposition. You must establish control early by making the expert answer your question. White-tailed deer numbers exist at or substantially above habitat potential (the ability of native habitat to support deer without sustaining long-term degradation or loss of plant species) in much of this sub-region. Every penny counts! 3 William Street Tranmere SA 5073; 45 Gray Street Tranmere SA 5073; 36 Hectorville Road, Hectorville, SA 5073; 1 & 2/3 RODNEY AVENUE, TRANMERE; 9 Frederick Street Magill SA 5072; Completed Projects. 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. 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. 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. The city of Arlington, Texas lies within this zone, and Denton and Cleburne are on its eastern edge. Washington Irving, in 1835, described it as "like struggling through forests of cast iron. His remaining testimony is not credible because common sense tells you the document represented what was true at the time it was written. Or perhaps this witness will just be combative-either way, there are ways to control such witnesses effectively. Every person works hard to collect different property, investments, and assets throughout their life. 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, expert witnesses in the medical field have a tendency of using technical terms such as radial, distal and proximal, which may be difficult to understand. You must elicit that information so, among other things, your own expert will be able to identify points of criticism or disagreement. The company plans to . Be sure to review your outline before the end of a deposition to confirm that you did not miss points that you wanted to address. [5] The prairie portions are chiefly tallgrass on finer, dry soils. Weathering occurs when water breaks down rocks and soil to create sediment. Its market capitalization is minuscule, but its dividend is quite large. We have the experience to deliver. Some of the areas underlain by deep sands support a growth of tall grasses. West Cross Timbers - In Northcentral Texas, the West Cross Timbers vegetative sub-region, located immediately west of the Fort Worth Prairie and north of the Lampasas Cut Plain, extends from the Red River in Montague and Cooke counties south and southwestward to the Lampasas Cut Plain and west to the Rolling Plains. E-Newsletter Archive. al. Plus, Cross Timbers pays a monthly dividend. [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. because the big rock has more volume than the small rock, the water has more atoms to break down for the big rock to be broken. Expert witnesses may respond poorly to perceived hostility on cross-examination. [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. In the Fort Worth Prairie and Lampasas Cut Plain, shallow soils were formed over Cretaceous limestone parent materials. Often, an expert such as a treating doctor who is not an outright advocate for the other side will concede points when appropriate. Either by nature or by circumstance, some witnesses will not remember important details, or claim not to remember important details. Numerous roads cross this region, including US 70 in Oklahoma and I-20, I-30, US 67, US 81, US 82, US 180, US 183, US 281, US 287, and US 380 in Texas. Home; Projects. II. We understand the need to use the highest quality reporter for you. Anonymous, If you are not ready to return to in-person depositions, you can continue to use alternative ways to remotely attend depositions and access case files effectively. Accordingly, use your documents to weave your testimony on cross-examination. On June 19, 2014, Burger initially filed a Complaint in the United States District Court of the Southern District of Ohio. Early travelers called this region the Monte Grande (Grand . When you plot out cross examination, go carefully through the documents, especially the e-mails. Direct link to I am Rhys's post Fjarrgljfur looks like, Posted 2 months ago. Another strategy to handle this type of question is to say in some circumstances if that is the case. Retained experts are notoriously difficult to control, particularly for a new lawyer. Post oak-blackjack oak woodlands characterize much of the West Cross Timbers. The movement of water can create and modify features on Earths surface. The region from one river to the other, is no less bountifully supplied with buffalo, bear, deer, antelope, wild boars, partridges, and turkeys. The true value of depositions may be for impeachment purposes. "[16] Rachel Plummer, while a captive of the Comanche in 1836, described it as "a range of timber-land from the waters of Arkansas, bearing a southwest direction, crossing the False Ouachita, Red River, the heads of Sabine, Angelina, Natchitoches, Trinity, Brazos, Coloradothe range of timber is of an irregular width, say 5 to 35 miles wideabounding with small prairies, skirted with timber of various kinds oak, of every description, ash, elm, hickory, walnut and mulberrythe purest atmosphere I ever breathed was that of these regions. 5' #hj5 ob2Q9{Kv/r.:QyH#g& _6uf` ,M'vZS \\ \hVL`B`fBulO6&S@[q{r:kq?/Kx UudoFlC-x6|vwbvbmjT|OOQx yJ-C. You may be able to find information in the treatise or from one of the authors that contradicts the experts opinions. For example, if you know that a witness will not be available at trial and the deposition is being videotaped, you may want to treat the deposition as a cross-examination. Published by the Texas State Historical Association. Texas State Historical Association (TSHA) Is Alternative Dispute Resolution Right for You? If you can do it at trial, you can do it at a deposition, and a lot more. deposition, such as using exhibits and cross-examination. When preparing for cross, every question should be analyzed to see which of those three things are challenged. 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. Parks and Recreation. Discovery Litigation Services is skilled in Cross Timbers depositions and court reporting. 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. A: Yes. Extensive open grasslands and brushy rangelands occur in the West Cross Timbers sub-region. 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. The region features a limestone substrate as opposed to sandstone, and has greater topographical relief and denser and different vegetation than other parts of the Cross Timbers. Beginning in the eastern half of Cooke County, it extends southward through the eastern parts of Denton, Tarrant, and Johnson counties and the western parts of Grayson, Dallas, Ellis, and Hill counties. Email: CrossTimbers@uta.edu. 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 . This was an important influence on early settlement as underground water was available from shallow wells dug into the Trinity sands. The expert may provide an even more perfect setup for your next question than your question did. *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= Usually, it will take several narrative answers before you can expect the judge to step in and instruct the expert to respond, but asking for the judges help (if you get it) sends a powerful message that the expert is trying to be evasive. The towns of Sand Springs, Sapulpa, Ada, and Shawnee, Oklahoma fall within this large area; Bartlesville and Okmulgee lie on the eastern edge. cross timbers deposition. They are always waiting for you to give them an opportunity to reiterate their favorite themes. Witnesses do not talk to each other anymore. Schedule your Cross Timbers deposition today! Going on too long is one of the two most frequent causes of an unsuccessful cross examination. Our reporters that cover Cross Timbers are highly skilled in their craft, and they are ready to meet your specific case needs. Login (855) 847-0999 calendar@huseby.com Discover 4 parks within 8.3 miles, including Lewisville Lake Environmental Learning Area, Coppell Nature Park, and Coppell Community . [2] In turn, the Cross Timbers are themselves subdivided into nine Level IV Ecoregions: This is a wide belt of land stretching from south-central Oklahoma into southeastern Kansas and is the only part of the Cross Timbers that extends into Kansas. The best way to prepare your expert for facing difficult questions on cross is to practice them with your experts, if appropriate. 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. Soils of the East and West Cross Timbers were developed on sandy Cretaceous Woodbine and Trinity strata. 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. Vast tall-grass native prairies once covered this region. The most important tip to remind your witness is to stop, breathe and think about the question being asked before providing an answer. If you change your mind, you can easily unsubscribe. 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. You must reduce the issue you are addressing to a knowledge level that will convince the judge that what the expert has sold them on direct is inconsistent with the common sense that you will be emphasizing they need to use to decide the case in closing argument. Sure Dividend has compiled a database of 84 . Judges hate repetition anyway because they are tired enough of the trial and dont want to watch the same hand played again. 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. You should use these concessions to the extent possible to support your case. The Cross Timbers are defined by the United States Environmental Protection Agency as Ecoregion 29, a Level III ecoregion. A: Yes. The diversity and configuration of plant communities on the landscape influence wildlife populations. Do not let the expert move from a topic if you think it has not been sufficiently addressed. Toward the south the Eastern Cross Timbers belt spans the ninety-seventh meridian from the Red River to the Brazos River. So basically if I added water to rock paper scissors, I would win each of them? 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/. The average width of the Eastern Cross Timbers does not exceed fifteen miles, and its features disappear near the Brazos at Waco. Most of the timber appears to be kept small by the continual inroads of the "burning prairies;" for, being killed almost annually, it is constantly replaced by scions of undergrowth; so that it becomes more and more dense every reproduction. Therefore, acid rain is far too weak to negatively affect your skin in any way. When only one party serves the notice, that party gets to depose the witness as direct examination. The trees served as a testament to the harshness of the environment. First, do not argue with the witness. Do not take an opposing experts deposition until you have a firm outline and strategy for accomplishing your goals with the expert witness; otherwise, you are not likely to have any success either undermining or limiting the impact of the expert. c. Effective Use of Evidence/Documents in Examination. Development plans. A: Yes. Coca-Cola is not strong enough to dissolve skin. %%EOF 26 Downer Avenue Campbelltown SA 5074; [8] I-35 and I-35W cross north to south, while US 82, US 380, I-30, I-20, US 377, and US 67 cross east to west; US 81 and US 287 also cross southwest to northeast. Direct link to DRAKEB's post I don't know. In this situation, you will want to understand what the witness will say and establish points that you want to focus on in the deposition by using wide-ranging and more open-ended questions. 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. (see LOWER PLAINS.). The Cross Timbers and Prairies Ecological Region of Texas encompasses approximately 26,000 square miles in north and central Texas and is the primary ecological region of Northcentral Texas. Recreational activities near Pinewood Hills Independent Senior Living Apartments are plentiful. Features of the Fort Worth Prairie extend into the West Cross Timbers along the eastern boundary, forming irregular ecotones of diverse tree and brush species common to both zones. H@O@WF A Fragmentation of wildlife habitat is also rapidly increasing in the eastern counties of the West Cross Timbers where larger land holdings are being subdivided and sold as small home building site, farms and ranchettes. He lied when he wrote it? 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. Throughout its current range, the Cross Timbers forest ecosystem is vulnerable to land-use change. Texas Farm and Ranch Land Conservation Program, Wildlife Management in North Central Texas. Q: And that-to use your words-concerned you, isnt that true? Q: In fact, you anticipated that the contract production requirements were not met, isnt that true? They may be considered as the "fringe" of the great prairies, being a continuous brushy strip, composed of various kinds of undergrowth; such as black-jack, post-oaks, and in some places hickory, elm, etc., intermixed with a very diminutive dwarf oak, called by the hunters, "shin-oak." When examining this type of witness, it is particularly important to ask short, concise questions that are statements of fact. In most jurisdictions, re-direct is limited to matters that were covered on cross. 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. 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. Considerable urban growth and expansion throughout this region will continue to impact wildlife habitat resources in the future. 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?
Evergreen Funeral Obituaries,
Nancy Morgan Obituary Massachusetts,
Wilkerson Funeral Home Reidsville, Nc Obituaries,
Florida Vehicle Registration Number For College Application,
Articles C