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. Witnesses do not talk to each other anymore. why does acid rain dissolve rocks but not us humans? More likely, confronted with the e-mails memorializing of the witnesss contemporaneous statement, the witness is bludgeoned into an admission of yes. 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. Do not let an expert push you around. The towns of Sand Springs, Sapulpa, Ada, and Shawnee, Oklahoma fall within this large area; Bartlesville and Okmulgee lie on the eastern edge. 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. Whether you need videographer services, interpreter services, or something even more unique, we have the personnel and service culture to make your deposition as seamless as possible. The minute you are arguing with the witness, you are not going to win. Feb 2014 Friends. u+W Go|iATB5B!te=MPY ~2@Y;(JB~7@$ V! @"\X^qOy$)EG:skr cM+k]a|jA`W>rkI *i68i=.UhsMNdU2~&o r.J"~e(^MTmvAU/ 5h5 iSUg3w|I-j5X W]BZg4Hw vX$ For example, if a witness may not be at trial, you do not want to have that witness give responses adverse to your client; you should then be wary of open-ended questions (e.g., what happened next?). Our professionals are experienced in cases of all sizes. Published by the Texas State Historical Association. If you are using documents, consider marking up the documents or drafting your questions on the documents, this can allow you to do follow-up questioning for each document as you go through the deposition. His remaining testimony is not credible because common sense tells you the document represented what was true at the time it was written. This page was last edited on 17 February 2023, at 08:53. While planning for your future may seem like a daunting task, When one person in a couple is in the military, their divorce may be substantially different from a traditional civil divorce. 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. Coca-Cola is not strong enough to dissolve skin. The deposition of an expert witness is the culmination of the opposing party's defense or prosecution theory of the case. The Pennsylvanian outcrops form a plateau dissected by the channels of major streams that have been cut considerably below the surface level. 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. The average width of the Eastern Cross Timbers does not exceed fifteen miles, and its features disappear near the Brazos at Waco. The portion of the Western Cross Timbers underlain by the Wichita formation is a hilly and maturely dissected; in it the woodland vegetation is more scattered and more dwarfed than is the case in eastward-lying areas of the region. Expert witnesses may respond poorly to perceived hostility on cross-examination. "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. 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. If its objectionable, you as the attorney will take care of it. Direct link to Kayla Stout's post Is chemical or mechanical, Posted 5 months ago. [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]. Exposed sandstone rocks and boulders dominate landscape features in many areas. By reading the statement into the record, you are driving home its content in a far more effective way than by just authenticating the document. It passes through northwestern Grayson County, eastern Cooke, Denton and Tarrant counties, central Johnson County, western Hill County, and northern McClennan County. 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. 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. Counties found in the sub-region include parts of Somervell, Erath, Hamilton, Comanche, Brown, Mills, Bosque, Hill, and McLennan counties. Second, within that framework, determine what you hope to accomplish through the deposition. Direct link to braalt02's post Yes. Manage My Subscriptions, archive Every penny counts! They have a great selection of Texas wines that run the gamut from sweet to dry and whit to red. Even if you do nothing else while deposing an expert witness, at least make sure you confirm that the expert has told you all his or her opinions about the case. al. 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. The thick growth formed an almost impenetrable barrier for early American explorers and travelers. Two fragments adjacent to This change in plant life on the landscape, however, has increased habitat for a number of wildlife species and can be viewed as a positive result of historical land use in the Lampasas Cut Plain. In our business, there is no margin for error. What is the witness to do? TPWD:Cross Timbers - Texas Trisha M. Rich, Effectively Examining the Difficult Witness, Trying Your First Case: A Practitioners Guide, (April 2014), http://www.americanbar.org/content/dam/aba/administrative/litigation/materials/2014_sac/2014_sac/trying_your_first_case.authcheckdam.pdf/. The Cross Timbers are defined by the United States Environmental Protection Agency as Ecoregion 29, a Level III ecoregion. The point is that you must have an outline and a strategy for your deposition of an expert. 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. In pioneer times the band of timber was a famous landmark. 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. Review your understanding of weathering and erosion in this free article aligned to NGSS standards. c. Effective Use of Evidence/Documents in Examination. You also want to avoid being surprised. There are other considerations that will guide your questioning style. 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. lB)Onw@HO l MKulu#9315a;3CIc(@F.42D$90IdqD-1)#^ xx 6y|-&oO RFl_KnOUP)X}Plgj0JX`m#ruo%jL'}{X q1'vQ ;O=s9kHxaKh0$RWq uo8/{E'&KJpi']}q{LG? What evidence of weathering erosion and deposition exists in - Answers Direct link to jacobson.mia's post Can erosion happen fast t, Posted 5 months ago. S. Fort Worth, Texas 76118. Remind your expert of the role that he plays during direct examination and the litigation generally. The other party only gets to cross examine the witness. 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? People spontaneously write e-mails without hesitation and, more importantly, without reflection or thinking. Failing to listen to the answers you are getting is the next most common pitfall. 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. Argyle ISD Board approves resolution of - Cross Timbers Gazette Terms of Use | Privacy Policy Cross Timbers Ecosystem | Cross Timbers Urban Forestry Council The Eastern and Western Cross Timbers are formed by a narrow band of woodland extending along Red River. Is Alternative Dispute Resolution Right for You? 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. 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. That means your side must come across as reasonable and polite. 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. accessed May 01, 2023, 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. Beyond that, with respect to each opinion the expert has, make sure you ask the expert to exhaustively identify all the bases for each. Plus, Cross Timbers pays a monthly dividend. All rights reserved. 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 Main Belt and the Fringe together, though much interrupted, occupy the major portion of an area 150 miles long, varying in width from about 25 miles at the north to about 110 miles at the south.". You get the resources of a large divorce and family law firm AND the attentive service of a local attorney. 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. 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. If the witness will be available at trial, your purpose more likely will be to elicit the witnesss story. That can lead to a lengthy, tedious cross that does not capture the judges attention. Our reporters that cover Cross Timbers are highly skilled in their craft, and they are ready to meet your specific case needs. Private message. [6] More specifically, the Cross Timbers fall into Level II Ecoregion 9.4, the smaller South Central Semi-Arid Plains. 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. 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. It is effective to have the witness repeat what he or she wrote and then merely ask if the witness believes it to be a true statement at the time he or she wrote it. 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. The trees served as a testament to the harshness of the environment. In some places, however, the oaks are of considerable size, and able to withstand the conflagrations. Parks and Recreation. The most knowledgeable expert in the world will do little to help your case if the judge is asleep. Eliciting Deposition Testimony: Real-World Application of Techniques. Every dollar helps. When only one party serves the notice, that party gets to depose the witness as direct examination. Cross Timbers Royalty Trust (CRT) is a micro-cap, and a tiny one at thatit has a market capitalization of just $145 million. When preparing for cross, every question should be analyzed to see which of those three things are challenged. 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. Save that effort for when you have your own expert on the stand and she is willing to cooperate in your educational endeavor. The region from one river to the other, is no less bountifully supplied with buffalo, bear, deer, antelope, wild boars, partridges, and turkeys. They are always waiting for you to give them an opportunity to reiterate their favorite themes. 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. Discuss tips with your expert, if appropriate, on how to rephrase some technical explanations and make them easier to understand. What Distinguishes a Military Divorce From Other Types of Divorces? Portions of the Trinity sands area are now important in peanut culture as well as for the growing of small fruits. This region contains the cities of Fort Worth, Granbury and Denton, although Denton lies on the border with the Eastern Cross Timbers. Leasing land for deer hunting is an important economic enterprise of the sub-region. [3] The western suburbs of the Tulsa metropolitan area and the northeastern suburbs of the Oklahoma City metropolitan area also lie within this area. The towns of Duncan, Oklahoma and Walters, Oklahoma, lie in this region.[2]. These experts may be susceptible to being put into a box for purposes of cross-examination. Daniel P. Dain, How to Prepare for, Take, and Use a Deposition, Attorney Education Center, https://www.jameseducationcenter.com/articles/deposing-expert-witnesses/. (Was that what you meant by 'Which one is more comman'). PDF Structure, Composition, and Regeneration of Cross Timbers Forest Indians used the Cross Timbers as a north-south avenue that afforded secrecy from enemies. 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. Its location was well known and served as a landmark reference for travelers. 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. We have the experience to deliver. endstream endobj startxref One of the best ways to get judges to interact with the experts testimony is to make his or her methodology both easy to understand and easy to use. When you choose us, you dont have to sacrifice quality or service. Remember the cardinal rule of cross examining and ask only short and simple factual statements. [3], Geologically speaking, the Cross Timbers are underlain by Pennsylvanian and Cretaceous-era sandstone and limestone that has been moderately dissected, giving the region a gently to moderately rolling topography,[3][4] including some cuestas. 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. The Trinity sands area at the east is a plain much of the surface of which is now so eroded as to forbid its use agriculturally. A: Yes. Ask an expert who and what is considered authoritative in the field. This sub-region has a complex geologic history, resulting in a variety of soil types, terrain features, and vegetative plant communities. with let's say a sm, Posted 3 months ago. Everyone knows this rule, but everyone also fails to follow it diligently. Best Winery In Grapevine. Call Discovery at (855) 847-0999. Remind your witness that I dont know is a perfectly acceptable answer, as long as that is the truth. 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 Royalty Trust (CRT) - Stock Analysis 2261 0 obj <> endobj Considerable urban growth and expansion throughout this region will continue to impact wildlife habitat resources in the future. The areas of ancient Cross Timbers still remaining are some of the last virgin North American hardwood forests. You are paying a significant amount for the deposition, so get your moneys worth. Some organizations and maps refer to the Cross Timbers ecoregion as the Central Oklahoma/Texas Plains. If you change your mind, you can easily unsubscribe. Cross Timbers | The Encyclopedia of Oklahoma History and Culture If you find that the cross is going to take longer than that, you should seriously consider cutting it back. All rights reserved. Reveal number. Direct link to I love Isabelle's post Mechanical weathering is , Posted 6 months ago. The ending is what everyone always takes away. What does matter is getting the witnesss own words in writing into evidence before the judge. Crow Holdings has submitted to the town of Flower Mound a site plan proposal for the Cross Timbers Business Park, a 10-building warehouse park in the northwest corner of FM 1171 and Hwy 377. https://www.tshaonline.org/handbook/entries/cross-timbers. 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. (see LOWER PLAINS.). 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. You must elicit that information so, among other things, your own expert will be able to identify points of criticism or disagreement. Highways also cross the area.[2][3]. The movement of water can create and modify features on Earths surface. 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. Here, it almost does not matter what the witness says. 4 Y`c<6 #(@N1r 7maaX#vA 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. Today, few large tracts of undisturbed woodlands remain in the East Cross Timbers which is perhaps the most fragmented vegetative region in Texas. Cross Timbers Royalty Trust operates as an express trust in the United States. Current Projects. First, consider whether the case is likely to proceed to trial. The natural vegetation is a woodland predominantly made up of dwarfed post oaks. Another strategy to handle this type of question is to say in some circumstances if that is the case. 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. With an overly detailed outline, you are more likely to stick to it in the deposition than to listen to the answers and be able to follow up with some flexibility. In most jurisdictions, re-direct is limited to matters that were covered on cross. Watersheds of the Red, Colorado, Trinity and Brazos Rivers cross the region from northwest to southeast. See additional disclaimers, MISSOURI, ILLINOIS, KANSAS, OKLAHOMA, & NEBRASKA FAMILY LAW ATTORNEYS, Charitable Giving and Community Involvement. Comanches raided east of the Cross Timbers in the early years, and the Wichitas and others used the wood in the Cross Timbers. We'll send you a couple of emails per month, filled with fascinating history facts that you can share with your friends. The Cross-Timbers region of the United States, situated in the southern Great Plains along the western edge of the eastern deciduous forest, was historically Quercus-dominated open forest interspersed with tallgrass prairie and shrubs communities. This way, your witness does not call out uncertain answers based on a pressure to perform. 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. Vast tall-grass native prairies once covered this region. Q: And that-to use your words-concerned you, isnt that true? 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. The pH of acid-impacted rain is generally below 4.5 on the pH scale. The second point in conveying a recognizable methodology to judges is creating familiar examples and analogies for the judge. In addition to not letting an expert push you around, you must be persistent in following through with your line of questions. Direct link to neela's post why does acid rain dissol, Posted a month ago. This field is for validation purposes and should be left unchanged. If you are careful about not opening up subjects that you know are likely troublesome, you may be able to prevent questions on those subjects during re-direct. How acidic is Acid Rain and how does it happen. Mechanical weathering is the creation of sediment through physical means. Some exposed surface formations in the western part of the West Cross Timbers date from the 300-million-year-old Pennsylvanian Period. If the only people in the courtroom who realize how effectively you have gutted the oppositions expert are you and the expert, then the expert has won and you have lost. 2272 0 obj <>/Filter/FlateDecode/ID[]/Index[2261 27]/Info 2260 0 R/Length 69/Prev 462257/Root 2262 0 R/Size 2288/Type/XRef/W[1 2 1]>>stream 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. ", Other historic accounts by early travelers in north and central Texas record a much different Texas landscape in many areas that is difficult for us to imagine today. Your contact information is used to deliver requested updates or to access your subscriber preferences. 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. endstream endobj 2266 0 obj <>stream Considerable farming and livestock grazing operations were initiated by early settlers in areas of sufficient soil depth in this sub-region. The Eastern (or Lower) Cross Timbers, a narrow band of blackjack and post oak, separates the region of Black Prairies on the east from the Grand Prairies on the west. Cotton and corn are also grown. Your ability to smoothly demonstrate that you have a true mastery of the subject that you are discussing with the expert, while satisfying to you, is of no benefit to the judge. He lied when he wrote it? The terrain in most of this sub-region is very hilly, with sandstone and limestone escarpments, steep slopes, and irregular surface features. 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. Q: When you wrote in that e-mail you were concerned about meeting the production deadline under the contract, that was a true statement when you wrote it, was it not? Although habitat for wildlife is present throughout the ecological region as a whole, populations vary considerably within sub-regions. We are drowning in a flood of e-mails, and they are all part of e-discovery. The Arbuckle Mountains are located in a small area nestled in between regions 29g and h; it is made of folded, rather than dissected, limestone, sandstone, and dolomite, and features the greatest topographical relief of the entire Cross Timbers, though not the highest elevations. ", In 1840, Col. Email: CrossTimbers@uta.edu. 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. Rainfall is highly variable in this region, averaging about 25 inches in the western reaches to 35 inches in the east. cross timbers deposition 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. You may be able to find information in the treatise or from one of the authors that contradicts the experts opinions. cross timber: [noun] a strip of woodland chiefly of oaks stretching across grassland especially in Texas. Elevations across the region range from 500 to 1,500 feet. Discover 4 parks within 8.3 miles, including Lewisville Lake Environmental Learning Area, Coppell Nature Park, and Coppell Community . Direct link to tollitre000's post how does it start, Posted 4 days ago. The greater the familiarity, the greater the acceptance. Avoiding repetition prevents the expert from fixing an answer that he has previously given and would like an opportunity to correct. 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. Cross Timbers, Login (855) 847-0999 calendar@huseby.com 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 . Sustainability | Free Full-Text | Sustaining Cross-Timbers Forest Mark A. Neubauer, Mastering the Blind Cross-Examination, ABA Litigation, Volume 35, Number 2, (Winter 2009), https://apps.americanbar.org/litigation/litigationnews/trial_skills/tips-blind-cross-examination.html/. 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. If the last area of questioning finishes off the experts credibility, you have one.

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