III. S. Fort Worth, Texas 76118. 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. They are always waiting for you to give them an opportunity to reiterate their favorite themes. Expert witnesses may respond poorly to perceived hostility on cross-examination. Indians used the Cross Timbers as a north-south avenue that afforded secrecy from enemies. 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. Lay them out like a long mosaic and weave them back together as you tell your story through cross-examination. Occupying east and west a belt of one hundred miles in width, with about equal quantities of prairie and timber, intersected by numerous clear, fresh streams and countless springs, with a gently undulating surface of prairie and oak openings, it presents the most charming views, as of a country in the highest state of cultivation, and you are startled at the summit of each swell of the prairie with a prospect of groves, parks and forests, with intervening plains of luxuriant grass, over which the eye in vain wanders in search of the white village or the stately house, which seem alone wanting to be seen". Some organizations and maps refer to the Cross Timbers ecoregion as the Central Oklahoma/Texas Plains. u+W Go|iATB5B!te=MPY ~2@Y;(JB~7@$ V! @"\X^qOy$)EG:skr cM+k]a|jA`W>rkI *i68i=.UhsMNdU2~&o r.J"~e(^MTmvAU/ 5h5 iSUg3w|I-j5X W]BZg4Hw vX$
2022 by Stange Law Firm, PC. 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. You may learn the expert considers your experts work to be authoritative, or that the expert considers a treatise in which your expert is published to be authoritative. You are paying a significant amount for the deposition, so get your moneys worth. Elicit all the experts opinions and bases of opinions. In others, cross is open and can be directed to any subject that is relevant even if not addressed on direct. In re Elk Cross Timbers Decking Mktg. - Casetext Leasing land for deer hunting is an important economic enterprise of the sub-region. The East Cross Timbers - In Northcentral Texas, the East Cross Timbers vegetative sub-region is a narrow strip of timbered country extending from eastern Cooke County on the Red River south to western Hill County and includes portions of Denton, Tarrant, Johnson, and Hill counties. The term Cross Timbers, also known as Ecoregion 29, Central Oklahoma/Texas Plains, is used to describe a strip of land in the United States that runs from southeastern Kansas across Central Oklahoma to Central Texas. Good experts have probably spent several times as many hours on cross in a courtroom as you have. There are other considerations that will guide your questioning style. [4] The Cross Timbers are contained within the WWF central forest-grasslands transition ecoregion. LOCATION. [1] Made up of a mix of prairie, savanna, and woodland,[2][3] it forms part of the boundary between the more heavily forested eastern country and the almost treeless Great Plains,[2][3][4] and also marks the western habitat limit of many mammals and insects. endstream
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So basically if I added water to rock paper scissors, I would win each of them? Deposition and Court Reporting in Cross Timbers, Missouri 65634 Remember the cardinal rule of cross examining and ask only short and simple factual statements. Eliciting Deposition Testimony: Real-World Application of Techniques. H|OO@)HvBBMla=v=]@=4sIFv["iARDk5O $88][D4,)rs}%(DL`_"_"qw7)Ebh@iOUm Y2+kCunCQI olW 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. 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. 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. Anonymous, 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. Your questioning style may be open-ended like a direct examination, narrow and controlling like a cross-examination, or a combination of the two. 2272 0 obj
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Posted on Nov 14, 2016.
Direct link to tollitre000's post how does it start, Posted 4 days ago. 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? 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. 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. 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. The priority is and always should be not to compromise the credibility or image of your witness to the judge. Discuss tips with your expert, if appropriate, on how to rephrase some technical explanations and make them easier to understand. The areas of ancient Cross Timbers still remaining are some of the last virgin North American hardwood forests. 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? All rights reserved. Also, when it comes to the judges perception, you want to continue to make sure you are the one who looks credible and forthcoming. 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. Everyone knows this rule, but everyone also fails to follow it diligently. WHAT DOES AN IN-PERSON DEPOSITION LOOK LIKE? 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. *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= 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. 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." That means your side must come across as reasonable and polite. Other factors such as fragmentation of once continuous habitat into smaller land holdings, competition for food and cover with livestock, conversion of woodland habitat to improved pastures or other agricultural enterprises, urban and rural developments, and lack of proper wildlife and habitat management also determine the density and diversity of wildlife. This region contains the cities of Fort Worth, Granbury and Denton, although Denton lies on the border with the Eastern Cross Timbers. These experts often are minimally credible, because they are unwilling to concede any point, even when the point is beyond dispute. It passes through northwestern Grayson County, eastern Cooke, Denton and Tarrant counties, central Johnson County, western Hill County, and northern McClennan County. How you ask questions at a deposition depends upon your purpose in that deposition. This broad vegetative region also extends northward into Oklahoma and southern Kansas. Other associated woody species include shin oak, Spanish oak, live oak, Texas ash, mesquite, osage orange, Ashe juniper, eastern red cedar, cedar elm, skunkbush sumac, elbowbush, lotebush, tasajillo, rough-leafed dogwood, flame-leaf sumac, hawthorn, and hackberry. [2] I-35 crosses this region north to south. We understand the need to use the highest quality reporter for you. 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. 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. They stretch from southeast Kansas through central Oklahoma to just north of Waco, Texas. "[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. Terms of Use | Privacy Policy MKulu#9315a;3CIc(@F.42D$90IdqD-1)#^
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;O=s9kHxaKh0$RWq uo8/{E'&KJpi']}q{LG? The Eastern (or Lower) Cross Timbers, a narrow band of blackjack and . Direct link to Mahiro's post I have a river in my back, Posted 2 months ago. Save the Ultimate Point for Summation. Is Alternative Dispute Resolution Right for You? 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. If the witness will be available at trial, your purpose more likely will be to elicit the witnesss story. 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. II. What is the witness to say? What evidence of weathering erosion and deposition exists in - Answers Early travelers called this region the Monte Grande (Grand . E-Newsletter Archive. Direct link to Levi's post Can acid rain dissolve hu, Posted 6 months ago. Toward the south the Eastern Cross Timbers belt spans the ninety-seventh meridian from the Red River to the Brazos River. This is extremely important, since your witness can only make statements that fall within the scope of your witness expertise and any statements made otherwise will be stricken from the record. 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. Discovery Litigation will cover your Cross Timbers deposition. 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 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. Argyle ISD Board approves resolution of - Cross Timbers Gazette The Eastern and Western Cross Timbers are formed by a narrow band of woodland extending along Red River.
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