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. You may be able to find information in the treatise or from one of the authors that contradicts the experts opinions. Note the way to phrase the question-a true statement at the time it was written. [5] These old-growth forests contain millions of post oak from 200 to 400 years old and red cedar over 500 years old. ", In 1840, Col. The true value of depositions may be for impeachment purposes. There are other considerations that will guide your questioning style. The priority is and always should be not to compromise the credibility or image of your witness to the judge. Recreational activities near Pinewood Hills Independent Senior Living Apartments are plentiful. No towns of any size lie within this area, although Possum Kingdom Lake and State Park do;[8] the region is crossed by US 180 and Texas State Highway 16. 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. 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. Discovery Litigation Services is skilled in Missouri/court Reporters Cross Timbers/ depositions and court reporting. ", without weathering, erosion isn't possible, so I'd say weathering. A: Yes. Cross Timbers APEX Accelerator at The UTA Research institute. Obviously, helpful opinions given by an opposing expert will be more valuable than if those opinions are coming from your own expert. It can be further subdivided into four ecological or vegetative sub-regions: East Cross Timbers, Fort Worth Prairie, Lampasas Cut Plain, and West Cross Timbers. Numerous roads cross this region, including US 70 in Oklahoma and I-20, I-30, US 67, US 81, US 82, US 180, US 183, US 281, US 287, and US 380 in Texas. 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/. Many trial judges create their own rules of courtroom behavior. 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/. 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. You must establish control early by making the expert answer your question. Children under 13 years of age must have a parent/guardian's consent before providing "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. 10. Accordingly, use your documents to weave your testimony on cross-examination. 2022 by Stange Law Firm, PC. It served as a dividing line between the hunting grounds of the Plains Indians and East Texas Indians. 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. [2] The area has also been an important site of oil extraction for over 80 years. 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. 5' #hj5
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\hVL`B`fBulO6&S@[q{r:kq?/Kx UudoFlC-x6|vwbvbmjT|OOQx yJ-C. First, consider whether the case is likely to proceed to trial. When you choose us, you dont have to sacrifice quality or service. Call Discovery at (855) 847-0999. 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. you may want to treat the deposition as a cross-examination . B. Sandy loam soils are productive for agricultural crops such as peanuts, small grains, fruit trees, sorghum, pecans, and truck crops. Direct link to braalt02's post Yes. ", Marcy (1866) stated of the Cross Timbers, "At six different points where I have passed through it (Cross Timbers), I have found it characterized by the same peculiarities; the trees, consisting principally of post-oak and blackjack, standing at such intervals that wagons can with out difficulty pass between them in any direction. with let's say a sm, Posted 3 months ago. In Cross Timbers, we will need to find a location to host your deposition. This field is for validation purposes and should be left unchanged. 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. 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. 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 trees served as a testament to the harshness of the environment. A: Yes. This happens through weathering, erosion, and deposition. Reveal number. In pioneer times the band of timber was a famous landmark. In other areas, limestone surface formations and shallow clay soils support grasslands and vegetative plant communities adapted to higher alkalinity. Copyright 2012 - 2023 Huseby, LLC. If not, consider whether that question should be dropped or recast. 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. II. If you have deposed an opposing expert based on a thoroughly prepared outline and strategy, then you should leave the deposition knowing how you will deal with the expert at the time of trial. [8] I-35 and I-35W cross north to south, while US 82, US 380, I-30, I-20, US 377, and US 67 cross east to west; US 81 and US 287 also cross southwest to northeast. This was an important influence on early settlement as underground water was available from shallow wells dug into the Trinity sands. If you are using documents, consider marking up the documents or drafting your questions on the documents, this can allow you to do follow-up questioning for each document as you go through the deposition. If the experts answers appear to defeat the credibility challenge posed by your questions, then you have lost and the expert has won. The best way to prepare your expert for facing difficult questions on cross is to practice them with your experts, if appropriate. Private message. Ignore the experts (possibly feigned) exasperation, and ask your questions. Email: CrossTimbers@uta.edu. It has budgeted $70-90 million for E&D spending this year. Review your understanding of weathering and erosion in this free article aligned to NGSS standards. 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. Indians used the Cross Timbers as a north-south avenue that afforded secrecy from enemies. Language links are at the top of the page across from the title. I have a river in my backyard and when the rainwater evaporates i can see the dirt that got eaten at by the rain :^. 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. Direct link to Mark's post Acid rain is about 100 ti, Posted 2 months ago. Nearly all surface rocks of the North Central Texas were deposited during the Cretaceous Period (145-65 millions years ago). The Western Cross Timbers is underlain by three larger groups of geologic formations: the Trinity sands of the Comanchean or Lower Cretaceous, the hard rocks of the various Pennsylvanian formations, and the Continental Red Beds materials of the Wichita formation in the Lower Permian. Direct link to salli's post "Acid rain is caused by t, Posted 7 months ago. The second point in conveying a recognizable methodology to judges is creating familiar examples and analogies for the judge. Coca-Cola is not strong enough to dissolve skin. 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. [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]. In fact, outcrops of the Paluxy sands are interspersed among calcareous materials to the east of the Trinity sands; without exception, the narrow belts of Paluxy sand outcrops support a growth of hardwoods, forming ribbons of woodland in an area where grasses would normally predominate. Daniel P. Dain, How to Prepare for, Take, and Use a Deposition, Attorney Education Center, https://www.jameseducationcenter.com/articles/deposing-expert-witnesses/. I am curious. The towns of Duncan, Oklahoma and Walters, Oklahoma, lie in this region.[2]. 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. When only one party serves the notice, that party gets to depose the witness as direct examination. The Cross Timbers divide the eastern forests and the southern plains and became the boundary between eastern Indian tribes and the Plains tribes. Managing the Holidays After a Divorce With Children. The thick growth formed an almost impenetrable barrier for early American explorers and travelers. 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. Sure Dividend has compiled a database of 84 . Toward the south the Eastern Cross Timbers belt spans the ninety-seventh meridian from the Red River to the Brazos River. Cross Timbers Royalty Trust operates as an express trust in the United States. We understand the need to use the highest quality reporter for you. 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. Direct link to I love Isabelle's post Mechanical weathering is , Posted 6 months ago. Cross Timbers winery is simply great. The Trinity sands outcrop is an important intake area for meteoric water that forms important aquifers to the east where the formation continues in the subsurface. Feb 2014 Friends. 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. "[17] Josiah Gregg described the Cross Timbers in 1845 as varying in width from five to thirty miles and attributed their denseness to the continual burning of the prairies.[18]. This region was called the Upper Timbers by early travelers due to its higher elevation. A: Yes. Cross Examination Rules, Strategies and Traps to Avoid. The Cross Timbers are a complex mosaic of upland forest, savanna, and glade that form the broad ecotone between the eastern deciduous forests and the grasslands of the southern Great Plains. For all yes or no questions, framing is key for both the expert and the cross-examiner. 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. If the expert refuses to answer a question, establish that on the record to set up a potential motion to strike the expert as a witness. 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. Topographic types in the region vary with the major geologic formations that outcrop in the area. In most jurisdictions, re-direct is limited to matters that were covered on cross. You are paying a significant amount for the deposition, so get your moneys worth. Rocks are left out in the rain, extreme heat and freezing cold, but we humans are not, so we don't "DISSOLVE", Course: Middle school Earth and space science - NGSS, Middle school Earth and space science - NGSS. cross timbers deposition. 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. The Pennsylvanian outcrops form a plateau dissected by the channels of major streams that have been cut considerably below the surface level. The movement of water can create and modify features on Earths surface. To log in and use all the features of Khan Academy, please enable JavaScript in your browser. Stiff (Dyksterhuis 1948) who approached the Cross Timbers of Texas from the western prairies stated, "In turning to the northeast, something much resembling an irregular cloud is dimly seen. 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. Save that effort for when you have your own expert on the stand and she is willing to cooperate in your educational endeavor. Elevation increases gradually from southeast to northwest. The landscape includes many caves, sinkholes, springs, and streams. Early travelers called this region the Monte Grande (Grand . 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? They are always waiting for you to give them an opportunity to reiterate their favorite themes. 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. Everyone knows this rule, but everyone also fails to follow it diligently. 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. Q: You knew there had been a delay in the manufacturing process, didnt you? Every dollar helps. Some rules may affect what you are allowed to do on cross examination. See additional disclaimers, MISSOURI, ILLINOIS, KANSAS, OKLAHOMA, & NEBRASKA FAMILY LAW ATTORNEYS, Charitable Giving and Community Involvement. and cookie statement. 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. Our professionals are experienced in cases of all sizes. The diversity and configuration of plant communities on the landscape influence wildlife populations. Remind your expert of the role that he plays during direct examination and the litigation generally. This happens through weathering, erosion, and deposition. When preparing for cross, every question should be analyzed to see which of those three things are challenged. Elicit all the experts opinions and bases of opinions. Winter agricultural forage crops such as wheat and oats are commonly planted. Talk with the expert, if truthful and appropriate, about not framing answers in a way to appears partial to one side or the other. Take the lead on how to engage the judge. Eliciting Deposition Testimony: Real-World Application of Techniques. The Main Belt and the Fringe together, though much interrupted, occupy the major portion of an area 150 miles long, varying in width from about 25 miles at the north to about 110 miles at the south.". 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 the #1 platform to conduct a deposition from the comfort of your home or office, providing you a first-class virtual deposition experience and live support from Huseby techs. Discovery Litigation Services is skilled in Cross Timbers depositions and court reporting. %%EOF
The portion of the Western Cross Timbers underlain by the Wichita formation is a hilly and maturely dissected; in it the woodland vegetation is more scattered and more dwarfed than is the case in eastward-lying areas of the region. Much of the sub-region contains habitat that supports populations of white-tailed deer and other wildlife species. The altitude of the belt is slightly higher than that of the surrounding prairies. That means your side must come across as reasonable and polite. ", 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. [9][10][12], Coal mining has historically been an important activity, as bituminous coal deposits are found throughout the region;[13] indeed, the town of Newcastle in Young County was named after the English city of the same name due to the coal connection. The woodland and savanna portions of the Cross Timbers are mainly post oak and blackjack oak on coarse, sandy soils;[4] fire suppression in recent years has increased forest density and allowed eastern redcedar to invade as well. Thus, its always advisable to simply tell experts to tell the truth. 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. If its objectionable, you as the attorney will take care of it. This region contains the cities of Fort Worth, Granbury and Denton, although Denton lies on the border with the Eastern Cross Timbers. And not using every single question seems to leave some of your great ideas at home. [5] The prairie portions are chiefly tallgrass on finer, dry soils. 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. The cross of a tough expert should seldom take more than one quarter of the time that was taken on direct. 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. Whether you need videographer services, interpreter services, or something even more unique, we have the personnel and service culture to make your deposition as seamless as possible. Yes. 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. 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. This sub-region has a complex geologic history, resulting in a variety of soil types, terrain features, and vegetative plant communities. What to do when a Witness is Being Evasive of Defiant. Direct link to Levi's post Can acid rain dissolve hu, Posted 6 months ago. HVpTWg6o@
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$!xt El-![OvA6`s*hIa]! Login (855) 847-0999 calendar@huseby.com 26 Downer Avenue Campbelltown SA 5074; In addition to not letting an expert push you around, you must be persistent in following through with your line of questions. Beyond discovering what happened, be clear on what two or three points you want to establish through a witnesss testimony. Login (855) 847-0999 calendar@huseby.com 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. In some jurisdictions, cross is strictly limited to the scope of direct. How you ask questions at a deposition depends upon your purpose in that deposition. Mechanical weathering is the creation of sediment through physical means. This is significant, since bias is a valid grounds for disqualifying an expert witness. {}~ysZ=*dv-v^AhYAuuBWy=(G0Y7eJd#YR2L$U4EB/t0 As you are walking the expert through the steps of their methodology, it is also important to ask them about what they were thinking as they looked at the data or results that they were seeing. [6] More specifically, the Cross Timbers fall into Level II Ecoregion 9.4, the smaller South Central Semi-Arid Plains. First, do not argue with the witness. 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. 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? endstream
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If a question is difficult to answer by simply stating yes or no, let your witness know it is perfectly fine to tell the questioning attorney that such a simple answer cannot be provided in that context. Beyond that, with respect to each opinion the expert has, make sure you ask the expert to exhaustively identify all the bases for each. Q: And that was the concern you wrote about in your e-mail, was it not, sir? 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." The ending is what everyone always takes away. 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. Therefore, acid rain is far too weak to negatively affect your skin in any way. Consequently, plant communities change dramatically within short distances resulting in different land use potential for livestock grazing, farming, wildlife management, or other uses. The most tornado-prone ecoregions in Texas are the Rolling Plains, the Cross-Timbers and Prairies, and the Blackland Prairies. MKulu#9315a;3CIc(@F.42D$90IdqD-1)#^
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The objective of cross examination of an expert is not to attempt to refute every point the expert has made on direct examination. They stretch from southeast Kansas through central Oklahoma to just north of Waco, Texas. Considerable urban growth and expansion throughout this region will continue to impact wildlife habitat resources in the future. https://www.tshaonline.org, https://www.tshaonline.org/handbook/entries/cross-timbers. %PDF-1.7
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Avoiding repetition prevents the expert from fixing an answer that he has previously given and would like an opportunity to correct. any personal information to the agency. Often what the expert says in response to a great question will provide the most powerful next question in your cross. Our court reporters, videographers, and team members have been educated on Huseby's in-person deposition guidelines. Discovery Litigation will cover your Cross Timbers deposition. Handbook of Texas Online, By getting your deposition on calendar now, our Schedulers and Case Managers can work closely with you to adjust or change your attendance options as needed. 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. 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". 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. Plaintiff Ken Burger ("Burger") is an Ohio citizen who resides in Cincinnati, Ohio. The terrain in most of this sub-region is very hilly, with sandstone and limestone escarpments, steep slopes, and irregular surface features. Current Projects. 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. If you doubt that, go back and look over the last cross examinations you have handled. 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. [2][4], In Oklahoma, this belt of woodland covers all of Marshall County and parts of Love, Carter, Johnston, and Bryan counties, but in Texas, this region exists as a long, very narrow strip of dense forest stretching from the Red River to just north of Waco, Texas. By reading the statement into the record, you are driving home its content in a far more effective way than by just authenticating the document. The Western Cross Timbers country presents a landscape unexpected in West Texas. c. Effective Use of Evidence/Documents in Examination. The minute you are arguing with the witness, you are not going to win. 4 Y`c<6 #(@N1r 7maaX#vA The areas of ancient Cross Timbers still remaining are some of the last virgin North American hardwood forests. "[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.