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If there is a good likelihood the case may be tried, you may want to hold some of your strongest attacks. |-!U`&w. Kjj(-(pJ|wRrAG NA{A$3HL1Q8%_  Here, it almost does not matter what the witness says. cross timber: [noun] a strip of woodland chiefly of oaks stretching across grassland especially in Texas. What is the witness to say? 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. Our court reporters, videographers, and team members have been educated on Huseby's in-person deposition guidelines. Q: And that was the concern you wrote about in your e-mail, was it not, sir? Every dollar helps. When you have prepared for hours or days to destroy an opposing expert, you become captivated by how powerful your carefully crafted outline is. Discover 4 parks within 8.3 miles, including Lewisville Lake Environmental Learning Area, Coppell Nature Park, and Coppell Community . Direct link to I am Rhys's post Fjarrgljfur looks like, Posted 2 months ago. You must establish control early by making the expert answer your question. 4 Y`c<6 #(@N1r 7maaX#vA 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. 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. The altitude of the belt is slightly higher than that of the surrounding prairies. The deposition of an expert witness is the culmination of the opposing party's defense or prosecution theory of the case. b. Translating Expert Testimony and Legalese into Plain English. Exposed flat topped buttes and escarpments capped by Edwards limestone which have been eroded over most of the region. Accordingly, use your documents to weave your testimony on cross-examination. 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. That can lead to a lengthy, tedious cross that does not capture the judges attention. Parks and Recreation. 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. (see LOWER PLAINS.). Published by the Texas State Historical Association. In essence, you are making the judge the expert. Current Projects. 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. Two fragments adjacent to Indians used the Cross Timbers as a north-south avenue that afforded secrecy from enemies. If not, consider whether that question should be dropped or recast. 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. County . Is chemical or mechanical weathering more common? 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. For lawyers learning how to take depositions, there are a few guiding principles to keep in mind and a number of traps to avoid. There are two main types of weathering: mechanical and chemical. Every person works hard to collect different property, investments, and assets throughout their life. 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. 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". Direct link to braalt02's post Yes. This region was called the Upper Timbers by early travelers due to its higher elevation. Numerous U.S. 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. You should use these concessions to the extent possible to support your case. 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. Deciding to end your marriage is never simple, especially when you know how difficult the process can be. The choice of a lawyer is an important decision & should not be based solely upon advertisements. 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. Direct link to Mark's post Acid rain is about 100 ti, Posted 2 months ago. Before taking an expert's deposition, the parties should have completed fact discovery-interrogatories answered, documents obtained, lay witnesses deposed. Vegetation on the landscape of the Cross Timbers and Prairies Ecological Region of Northcentral Texas has undergone significant changes over the past 150 years. Discovery Litigation will cover your Cross Timbers deposition. If the witness will be available at trial, your purpose more likely will be to elicit the witnesss story. When only one party serves the notice, that party gets to depose the witness as direct examination. The region is well adapted for truck farming. They merely e-mail each other. The landscape includes many caves, sinkholes, springs, and streams. Cross Timbers oaks are used for firewood, railroad ties, and poles, but the most important function of the timber belt is preserving water. The minute you are arguing with the witness, you are not going to win. Sometimes experts are advocates for the parties that have retained them. This strategy of beating them to the punch, so to speak, will not only catch opposing counsel by surprise and weaken their strategy on cross, but will also demonstrate that you and your expert have explored any potential problems in the testimony and have addressed them to the court vis--vis a proper counter argument or explanation. Austin: University of Texas Press, United States Environmental Protection Agency, "Ecological Regions of North America Level I", "Ecological Regions of North America Level I-II", "Descriptions of the Level IV Ecoregions of Texas", "TPWD: An Analysis of Texas Waterways (PWD RP T-3200 1047) Brazos River", "Brazos River Canyonlands The Brazos River", Texas counties map showing the ecoregion; similar to the above map. The region has been important chiefly for its mineral resources. The best way to prepare your expert for facing difficult questions on cross is to practice them with your experts, if appropriate. The region at large, underlain by nonlimy geologic materials, is not easily eroded; constructional areas are few, and where they do occur, at the foot of longer slopes, they are of small extent. The Eastern and Western Cross Timbers are formed by a narrow band of woodland extending along Red River. Farm and ranch size is relatively large, making accomplishment of land management strategies for wildlife and habitat both productive and feasible. Direct link to Levi's post Can acid rain dissolve hu, Posted 6 months ago. Q: In fact, you anticipated that the contract production requirements were not met, isnt that true? Portions of the Trinity sands area are now important in peanut culture as well as for the growing of small fruits. Recreational activities near Pinewood Hills Independent Senior Living Apartments are plentiful. It is bordered on the east by the Blackland Prairie Ecological Region, the west by the Rolling Plains Ecological Region, and extends south and southwestward to the Llano Basin and Edwards Plateau Ecological Region in central Texas. About 17 million acres are represented by this region of alternating bands of wooded habitat scattered throughout a mostly prairie region. Elevations across the region range from 500 to 1,500 feet. [2], No major metropolitan areas lie wholly within the Cross Timbers, although roughly the western half of the Dallas-Fort Worth Metroplex does, including the cities of Fort Worth, Denton, Arlington, and Weatherford. Short grasses occur over much of the area in localities where the woodland growth is sparse. ", 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. So basically if I added water to rock paper scissors, I would win each of them? The second point in conveying a recognizable methodology to judges is creating familiar examples and analogies for the judge. Whether invoking the often used recipe analogy for a patent, talking about lottery odds, or speaking about home or car loans, judges use analogies to understand the methods and reasoning used by experts because these anecdotes touch on an experience the judges themselves have had. [4] The Cross Timbers are contained within the WWF central forest-grasslands transition ecoregion. 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. The soil is thin, sandy, and poorly watered. This broad vegetative region also extends northward into Oklahoma and southern Kansas. 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. The Be Brief rule is hard to comply with if the same subject is covered several times. Manage My Subscriptions, archive Overgrazing by livestock and elimination of naturally occurring fire also reduced native grass cover and allowed the invasion of other less desirable annual grasses and forbs. 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. Much of the land in this region is also used for livestock ranching for cattle, sheep, and goats. 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. "F)YA`:KAls!G>;~ZO 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. 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 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. Ecologically, the EPA includes the Cross Timbers as part of the vast Great Plains, which comprise Level I Ecoregion 9.0, stretching from central Alberta in Canada to northern Mexico. 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. 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. Q: You knew there had been a delay in the manufacturing process, didnt you? These experts may be susceptible to being put into a box for purposes of cross-examination. 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?). with let's say a sm, Posted 3 months ago. The thick growth formed an almost impenetrable barrier for early American explorers and travelers. The Cross Timbers bands made travel difficult for settlers, yet the ecosystem provided for their basic needs. [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.