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Elicit all the experts opinions and bases of opinions. I. CPLR 3110 (1) A. The region from one river to the other, is no less bountifully supplied with buffalo, bear, deer, antelope, wild boars, partridges, and turkeys. PDF Weathering, Erosion, and Deposition: Trans Pecos/Chihuahuan Desert In essence, you are making the judge the expert. The other party only gets to cross examine the witness. TSHA | Cross Timbers - Handbook of Texas https://www.tshaonline.org, https://www.tshaonline.org/handbook/entries/cross-timbers. First, consider whether the case is likely to proceed to trial. There is nothing gained by appearing to become angry and frustrated by the experts unwillingness to concede points that she should obviously concede. All rights reserved. cross timbers deposition. 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. It has budgeted $70-90 million for E&D spending this year. This is significant, since bias is a valid grounds for disqualifying an expert witness. 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. and cookie statement. hVmoH+tw 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. PDF 6. FUNDAMENTALS OF DEPOSITIONS - New York State Bar Association If you doubt that, go back and look over the last cross examinations you have handled. The towns of Sand Springs, Sapulpa, Ada, and Shawnee, Oklahoma fall within this large area; Bartlesville and Okmulgee lie on the eastern edge. 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. they make everyone who enters the door feel like family. A: Yes. 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. endstream endobj startxref For lawyers learning how to take depositions, there are a few guiding principles to keep in mind and a number of traps to avoid. 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. Terms of Use | Privacy Policy WHAT DOES AN IN-PERSON DEPOSITION LOOK LIKE? 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. In others, cross is open and can be directed to any subject that is relevant even if not addressed on direct. 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. 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. [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. 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/. This was an important influence on early settlement as underground water was available from shallow wells dug into the Trinity sands. 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. 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". What is the witness to say? 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. 5' #hj5 ob2Q9{Kv/r.:QyH#g& _6uf` ,M'vZS \\ \hVL`B`fBulO6&S@[q{r:kq?/Kx UudoFlC-x6|vwbvbmjT|OOQx yJ-C. Direct link to neela's post why does acid rain dissol, Posted a month ago. In pioneer times the band of timber was a famous landmark. Anything else will surely land you in hot water-this witness will take advantage of any opportunity to derail your case with his version of what is important for the jury to know. [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. See, New Court Rules, infra. Beyond discovering what happened, be clear on what two or three points you want to establish through a witnesss testimony. Indians used the Cross Timbers as a north-south avenue that afforded secrecy from enemies. Retained experts are notoriously difficult to control, particularly for a new lawyer. If you find that the cross is going to take longer than that, you should seriously consider cutting it back. [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. Or perhaps this witness will just be combative-either way, there are ways to control such witnesses effectively. It should be expected that opposing counsel will try to pigeonhole the witness testimony this way, so be sure to go over this with your expert. Throughout its current range, the Cross Timbers forest ecosystem is vulnerable to land-use change. 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. You would cross-examine the witness in this type of deposition as you would at trial. More likely, confronted with the e-mails memorializing of the witnesss contemporaneous statement, the witness is bludgeoned into an admission of yes. The rich loam soils now support agricultural croplands that produce cotton, corn, oats, wheat, sorghum, milo, and other crops. In 1772, De Mezieres (Dyksterhuis 1948) stated that from the Brazos River north "one sees on the right a forest (East Cross Timbers) that the native appropriately call the Grand ForestSince it contains some large hills, and because of the great quantity of oaks, walnuts, and other large trees, it is a place difficult to crossOn the farther edge of this range, or forest, one crosses plains having plentiful pasturage;" and in 1778 "I crossed the Colorado and Brazos, where there arean incredible number of Castilian cattle, and herds of mustangs that never leave the banks of these streams. Direct link to jacobson.mia's post Can erosion happen fast t, Posted 5 months ago. 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. Parks and Recreation. Numerous U.S. 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. Soil and variations parallel both the topography and the geologic materials. Judges hate repetition anyway because they are tired enough of the trial and dont want to watch the same hand played again. [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]. Either the witness has to confess being a liar in writing an intentionally false e-mail or the witness has to acknowledge that he believed the e-mail to be true at the time written, regardless of the fact that a different truth dawned on the e-mail author later in the litigation or in the life of the dispute. II. The second point in conveying a recognizable methodology to judges is creating familiar examples and analogies for the judge. [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. The Cross Timbers divide the eastern forests and the southern plains and became the boundary between eastern Indian tribes and the Plains tribes. If the witness says, No, I do not believe my statement was true when I wrote it, then he is admitting he is a liar. You must establish control early by making the expert answer your question. Schedule your Cross Timbers deposition today! It was also a formidable obstacle to travelers because of the density of growth. Considerable urban growth and expansion throughout this region will continue to impact wildlife habitat resources in the future. Be persistent. 2287 0 obj <>stream Be persistent, but polite. why does acid rain dissolve rocks but not us humans? 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. It will be easy to get angry and frustrated with an evasive, non-responsive witness. The average width of the Eastern Cross Timbers does not exceed fifteen miles, and its features disappear near the Brazos at Waco. 10. If someone is going to argue, it should be the expert. If you did not ask that catchall question at the deposition and cover all of the opinions the expert has, and the expert then renders at trial opinions you were not aware of, your case could be endangered. The timber prevents rain water from immediately running off the surface and causes much of it to soak into sand that supplies artesian water for hundreds of wells to the east and south of the Cross Timbers. https://www.tshaonline.org/handbook/entries/cross-timbers. Cross Timbers stock has a high dividend yield of 8.8%. Some organizations and maps refer to the Cross Timbers ecoregion as the Central Oklahoma/Texas Plains. 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 These experts may be susceptible to being put into a box for purposes of cross-examination. See for yourself why so many call us their reporting company. Remind your witness to leave the door open for clarification on re-direct. 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. I have a river in my backyard and when the rainwater evaporates i can see the dirt that got eaten at by the rain :^. Remind your expert not to get defensive if they feel attacked by a line of questioning. 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." 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. cross timbers deposition. {}~ysZ=*dv-v^AhYAuuBWy=(G0Y7eJd#YR2L$U4EB/t0 hbbd``b`^$@$b8`v @"#"O 1999). [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. Consequently, plant communities change dramatically within short distances resulting in different land use potential for livestock grazing, farming, wildlife management, or other uses. 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. Rainfall is highly variable in this region, averaging about 25 inches in the western reaches to 35 inches in the east. Highways also cross the area.[2][3]. endstream endobj 2262 0 obj <>/OCGs[2274 0 R]>>/Pages 2246 0 R/StructTreeRoot 450 0 R/Type/Catalog>> endobj 2263 0 obj <>/Font<>/ProcSet[/PDF/Text]/XObject<>>>/Rotate 0/Type/Page>> endobj 2264 0 obj <>stream Deny that he wrote the document? c. Effective Use of Evidence/Documents in Examination. Argyle ISD Board considering resolution of - Cross Timbers Gazette Sustainability | Free Full-Text | Sustaining Cross-Timbers Forest Review your understanding of weathering and erosion in this free article aligned to NGSS standards. [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. Today, few large tracts of undisturbed woodlands remain in the East Cross Timbers which is perhaps the most fragmented vegetative region in Texas. Texas State Historical Association (TSHA) 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. Cross Timbers - Wikipedia The trees served as a testament to the harshness of the environment. No matter how many times an expert has testified at trial, being grilled during cross-examination is always incredibly stressful. Recreational activities near Pinewood Hills Independent Senior Living Apartments are plentiful. "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. Sandy loam soils are productive for agricultural crops such as peanuts, small grains, fruit trees, sorghum, pecans, and truck crops. Talk with the expert, if truthful and appropriate, about not framing answers in a way to appears partial to one side or the other. 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. When you choose us, you dont have to sacrifice quality or service. Is chemical or mechanical weathering more common? "F)YA`:KAls!G>;~ZO Find out which treatises or authors the expert considers to be authoritative in the field. He lied when he wrote it? endstream endobj 2265 0 obj <>stream 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. The landscape includes many caves, sinkholes, springs, and streams. "[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. After the introduction of domestic livestock, farming operations, and control of wildfires, the landscape of much of the Lampasas Cut Plain changed. a. 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. 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. Nice! Remind your witness that I dont know is a perfectly acceptable answer, as long as that is the truth. 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. 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. (Was that what you meant by 'Which one is more comman'). 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. Weathering, Erosion and Deposition: Cross Timbers and Prairies/Rolling Plains (9) The Crosstimbers and Prairies ecoregion and the Rolling Plains ecoregion lie west of the Blackland Prairies. Brainstorm with your expert better ways to present this information that will keep the judge interested in your experts testimony. In most jurisdictions, re-direct is limited to matters that were covered on cross. Anonymous, Direct link to Mahiro's post I have a river in my back, Posted 2 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. 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. Management of habitat for white-tailed deer and other wildlife species in the Lampasas Cut Plain sub-region can be financially rewarding to landowners and land managers. Its market capitalization is minuscule, but its dividend is quite large. Luckily, there are alternative methods to divorce. Instead, it might be better to use a pure discovery deposition to pin down what a witnesss story will be without revealing your best documents. In some jurisdictions, cross is strictly limited to the scope of direct. ", 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. 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/. If there is any significant doubt of who will win the point, leave the question on the cutting room floor. [2] Overall, the Cross Timbers are not as arable as the surrounding ecoregions. Much of the land in this region is also used for livestock ranching for cattle, sheep, and goats. Also, when it comes to the judges perception, you want to continue to make sure you are the one who looks credible and forthcoming. 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? Underlying layers of limestone slope eastward with the exposed ends of younger layers forming escarpments or "cuestas" that produce the scenic topography typical for the area. The easiest way to control a witness is through the use of exhibits. Avoiding repetition prevents the expert from fixing an answer that he has previously given and would like an opportunity to correct. How you ask questions at a deposition depends upon your purpose in that deposition. Call Discovery at (855) 847-0999. The soil is thin, sandy, and poorly watered. Early travelers called this region the Monte Grande (Grand . When a witness tries to interject his own answer to one of your questions, or otherwise refuses to answer, smile, and then offer to rephrase the question. The company plans to . We have the experience to deliver. This way, your witness does not call out uncertain answers based on a pressure to perform. If not, consider whether that question should be dropped or recast. What Are the Benefits of Having an Estate Plan? 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. [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.

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