The most important tip to remind your witness is to stop, breathe and think about the question being asked before providing an answer. Save that effort for when you have your own expert on the stand and she is willing to cooperate in your educational endeavor. There are other considerations that will guide your questioning style. County . 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. 2022 by Stange Law Firm, PC. u+W Go|iATB5B!te=MPY ~2@Y;(JB~7@$ V! @"\X^qOy$)EG:skr cM+k]a|jA`W>rkI *i68i=.UhsMNdU2~&o r.J"~e(^MTmvAU/ 5h5 iSUg3w|I-j5X W]BZg4Hw vX$ If you doubt that, go back and look over the last cross examinations you have handled. Leasing land for deer hunting is an important economic enterprise of the sub-region. TPWD:Cross Timbers - Texas We are a community-supported, non-profit organization and we humbly ask for your support because the careful and accurate recording of our history has never been more important. The ending is what everyone always takes away. 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. Ecoregion 5 - The Cross Timbers and Prairies. The region has been important chiefly for its mineral resources. Before taking an expert's deposition, the parties should have completed fact discovery-interrogatories answered, documents obtained, lay witnesses deposed. Its market capitalization is minuscule, but its dividend is quite large. If not, consider whether that question should be dropped or recast. Portions of the Trinity sands area are now important in peanut culture as well as for the growing of small fruits. In Cross Timbers, we will need to find a location to host your deposition. Discuss tips with your expert, if appropriate, on how to rephrase some technical explanations and make them easier to understand. Many woodland areas in this region have been cleared for tame-grass pastures, croplands, horse and cattle ranches, and urban and rural developments, including portions of the cities of Denton, Dallas, Fort Worth, and other expanding inter-city and rural communities. [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. 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. So basically if I added water to rock paper scissors, I would win each of them? 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." It is very important for you to generally remain the noble person who is confronting the expert. Direct link to evanlin0312's post water can melt/dissolve/b, Posted 6 months ago. 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 . You should use these concessions to the extent possible to support your case. al. Land use practices associated with these and other ventures created a landscape that experienced invasion and domination in some areas by problematic brush species such as mesquite, Ashe juniper and other native woody species. Deciding to end your marriage is never simple, especially when you know how difficult the process can be. 7300 Jack Newell Blvd. This collection by wildflower.org lists native plants local to the Texas part of 29. https://www.epa.gov/eco-research/ecoregion-download-files-state-region-6#pane-41, https://www.epa.gov/eco-research/ecoregion-download-files-state-region-7#pane-14, Cross Timbers Historic Images ProjectTexas, Oklahoma Digital Maps: Digital Collections of Oklahoma and Indian Territory, List of census-designated places in Kansas, List of unincorporated communities in Kansas, National Register of Historic Places Sites, 120 Coastal Western Hemlock-Sitka Spruce Forests, 6 Southern and Central California Chaparral and Oak Woodlands, 29 Central Oklahoma/Texas Plains (Cross Timbers), 56 Southern Michigan/Northern Indiana Drift Plains, 60 Northern Appalachian Plateau and Uplands, 83 Eastern Great Lakes and Hudson Lowlands, 104 Interior Forested Lowlands and Uplands, https://en.wikipedia.org/w/index.php?title=Cross_Timbers&oldid=1139874580, Temperate grasslands, savannas, and shrublands in the United States, Articles with dead external links from November 2019, Articles with permanently dead external links, Articles with dead external links from July 2020, Articles with self-published sources from January 2018, Creative Commons Attribution-ShareAlike License 3.0. Some rules may affect what you are allowed to do on cross examination. Everyone knows this rule, but everyone also fails to follow it diligently. First, do not argue with the witness. 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. Going on too long is one of the two most frequent causes of an unsuccessful cross examination. In Oklahoma, scientists found a 500-plus-year-old red cedar and a 400-year-old post oak in Keystone Ancient . This is significant, since bias is a valid grounds for disqualifying an expert witness. The proposed buildings would total nearly 3.3 . All rights reserved. We understand you may have questions about attending depositions in-person during COVID and we can help you tailor your deposition experience to your comfort level. 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. with let's say a small rock, sure it can take a while to break it down, but eventually the small rock will break but it won't take as long as it would for a big rock. Topographic types in the region vary with the major geologic formations that outcrop in the area. In our business, there is no margin for error. Your questioning style may be open-ended like a direct examination, narrow and controlling like a cross-examination, or a combination of the two. 0 Not only can we staff your deposition with a skilled court reporter, videographer and interpreter, Discovery Litigation Services will go above and beyond to fulfill your needs. [2], An extension in two branches of the Cross Timbers into southwestern Oklahoma, this area features reduced tree density and height, but also small forests dominated by sugar maple, bur oak, and live oak in deeper river canyons. Its location was well known and served as a landmark reference for travelers. Terms of Use | Privacy Policy The following, adapted from the Chicago Manual of Style, 15th edition, is the preferred citation for this entry. Post oak-blackjack oak woodlands characterize much of the West Cross Timbers. Copyright 2012 - 2023 Huseby, LLC. Cross Timbers Royalty Trust (CRT) is a micro-cap, and a tiny one at thatit has a market capitalization of just $145 million. 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. 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. 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. Toward the south the Eastern Cross Timbers belt spans the ninety-seventh meridian from the Red River to the Brazos River. Direct link to neela's post why does acid rain dissol, Posted a month ago. PDF Structure, Composition, and Regeneration of Cross Timbers Forest 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. Soils at the surface, consequently, support the growth of plants adapted to higher alkalinity, such as live oak and juniper. 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. In pioneer times the band of timber was a famous landmark. Talk with the expert, if truthful and appropriate, about not framing answers in a way to appears partial to one side or the other. account_circle 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. 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/. S. Fort Worth, Texas 76118. Judges will retain information better when they interact with that information. Every person works hard to collect different property, investments, and assets throughout their life. In the western counties, where the average size of land tracts increases, cattle ranching is the predominant land use. This region was called the Upper Timbers by early travelers due to its higher elevation. 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. Weathering occurs when water breaks down rocks and soil to create sediment. Hundreds of e-mails. Much of the sub-region contains habitat that supports populations of white-tailed deer and other wildlife species. By walking the judge through a point-by-point re-enactment of the experts methodology, it allows the judge to see what the expert is seeing as they are analyzing the subject matter. Early travelers called this region the Monte Grande (Grand Forest) and later the Lower Timbers. 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. The Be Brief rule is hard to comply with if the same subject is covered several times. This means that when opposing counsel asks your witness is that everything, it is crucial that your witness provides a flexible answer, such as that is all I can recall at the moment. Failure to do so may be grounds for impeaching your witness, or at the very least looks somewhat conflicting to the jury. Is chemical or mechanical weathering more common? For example, by allowing them to describe their impressions and reactions as they started going through their damages calculations or as they read the opposing experts report, it allows the judge to understand how the expert formed their final conclusions. Thousands of e-mails. 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/. The towns of Duncan, Oklahoma and Walters, Oklahoma, lie in this region.[2]. 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. Exposed flat topped buttes and escarpments capped by Edwards limestone which have been eroded over most of the region.
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