SOME BRIEF THOUGHTS ABOUT CROSS EXAMINATION
Good cross examination usually begins, not at trial, but with discovery. This is particularly true in connection with depositions. Much of our cross examination resource involves our depositions. The mistake most lawyers make is that they are not thinking about the jury when they are deposing a witness, they are thinking about motions and the witness. Lawyers tend to think that the witness is the audience but in fact the real audience is a jury which has not yet been…