cross timbers deposition

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. %%EOF Weathering, Erosion and Deposition: Cross Timbers and Prairies The landscape is categorized by irregular plains with acidic soils along the parallel ridges and valleys, sandy and sandy loam soils on the uplands, and clay and clay loams occupy the low-lying areas. Its location was well known and served as a landmark reference for travelers. When you plot out cross examination, go carefully through the documents, especially the e-mails. Leasing land for deer hunting is an important economic enterprise of the sub-region. 3 William Street Tranmere SA 5073; 45 Gray Street Tranmere SA 5073; 36 Hectorville Road, Hectorville, SA 5073; 1 & 2/3 RODNEY AVENUE, TRANMERE; 9 Frederick Street Magill SA 5072; Completed Projects. ", 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. When preparing for cross, every question should be analyzed to see which of those three things are challenged. The rich loam soils now support agricultural croplands that produce cotton, corn, oats, wheat, sorghum, milo, and other crops. The ending is what everyone always takes away. They may be considered as the "fringe" of the great prairies, being a continuous brushy strip, composed of various kinds of undergrowth; such as black-jack, post-oaks, and in some places hickory, elm, etc., intermixed with a very diminutive dwarf oak, called by the hunters, "shin-oak." and cookie statement. If the attorney insists on cutting off your witness, instruct your witness to answer the next question by stating the previous question was not completely or accurately answered. Early travelers through north Texas coined the name "Cross Timbers" by their repeated crossings of these timbered areas that proved to be a barrier to their travel on the open prairies to the east and west. If the witness will be available at trial, your purpose more likely will be to elicit the witnesss story. 4 Y`c<6 #(@N1r 7maaX#vA Cross Timbers winery is simply great. 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. The cross of a tough expert should seldom take more than one quarter of the time that was taken on direct. Our professionals are experienced in cases of all sizes. The following, adapted from the Chicago Manual of Style, 15th edition, is the preferred citation for this entry. In the Fort Worth Prairie and Lampasas Cut Plain, shallow soils were formed over Cretaceous limestone parent materials. If its objectionable, you as the attorney will take care of it. When you choose us, you dont have to sacrifice quality or service. The region from one river to the other, is no less bountifully supplied with buffalo, bear, deer, antelope, wild boars, partridges, and turkeys. Every person works hard to collect different property, investments, and assets throughout their life. 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. The objective of cross examination of an expert is not to attempt to refute every point the expert has made on direct examination. Cross Timbers stock has a high dividend yield of 8.8%. The soil is thin, sandy, and poorly watered. If the only people in the courtroom who realize how effectively you have gutted the oppositions expert are you and the expert, then the expert has won and you have lost. "[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]. If the case goes to trial, usually only a very small part of the deposition is ever used. Remind your expert not to get defensive if they feel attacked by a line of questioning. 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 Ellsworth expedition, accompanied by Washington Irving, entered the cross timbers in 1832; later he wrote, " It was like struggling through forests of cast iron." Indians used the Cross Timbers as a north-south avenue that afforded secrecy from enemies. Direct examination is your chance to paint the picture of your case to the judge, and when concerning an expert, the best chance to present your witness testimony. 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 tollitre000's post how does it start, Posted 4 days ago. That can lead to a lengthy, tedious cross that does not capture the judges attention. Direct link to Kayla Stout's post Is chemical or mechanical, Posted 5 months ago. Vegetation on the landscape of the Cross Timbers and Prairies Ecological Region of Northcentral Texas has undergone significant changes over the past 150 years. We need your support because we are a non-profit organization that relies upon contributions from our community in order to record and preserve the history of our state. More likely, confronted with the e-mails memorializing of the witnesss contemporaneous statement, the witness is bludgeoned into an admission of yes. Elicit all the experts opinions and bases of opinions. The towns of Sand Springs, Sapulpa, Ada, and Shawnee, Oklahoma fall within this large area; Bartlesville and Okmulgee lie on the eastern edge. Acid rain is about 100 times less acidic than Coca-Cola. Early travelers called this region the Monte Grande (Grand . I. CPLR 3110 (1) A. Ecoregion 5 - The Cross Timbers and Prairies. [3] Today, land use is a mixture of rangeland, pastures, and farmland. 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. 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. Elevations across the region range from 500 to 1,500 feet. You would cross-examine the witness in this type of deposition as you would at trial. Plaintiff Ken Burger ("Burger") is an Ohio citizen who resides in Cincinnati, Ohio. 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. In essence, you are making the judge the expert. Posted 6 months ago. They stretch from southeast Kansas through central Oklahoma to just north of Waco, Texas. account_circle 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. For example, if you know that a witness will not be available at trial and the deposition is being videotaped, you may want to treat the deposition as a cross-examination. Your contact information is used to deliver requested updates or to access your subscriber preferences. This change in plant life on the landscape, however, has increased habitat for a number of wildlife species and can be viewed as a positive result of historical land use in the Lampasas Cut Plain. cross timbers deposition. 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. Another strategy to handle this type of question is to say in some circumstances if that is the case. Terrain of the mostly treeless vegetative region, located north of the Brazos River, is characterized by gently sloping flat surface features with thin soil over hard layers of resistant limestone. Cross Timbers' acquisition strategy has given it a sizeable portfolio of drilling prospects. ", without weathering, erosion isn't possible, so I'd say weathering. 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. Do not let an expert push you around. Yes. Ford, J.S., 1963, Rip Ford's Texas. Before taking an expert's deposition, the parties should have completed fact discovery-interrogatories answered, documents obtained, lay witnesses deposed. 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. Cross Timbers, The short, stout oaks that grow in the Cross Timbers were not usable as timber, and those that were not cleared for farmland constitute one of the least disturbed forest types in the eastern United States (MADISON), with some 890,000 acres (3,600km2) of old-growth forest scattered throughout the region. The region is well adapted for truck farming. For example, instruct your witness that if there is some important portion of testimony that needs to be included, then the witness should take the liberty of saying what needs to be said. According to the University of Arkansas Tree Ring Laboratory, the Cross Timbers contain millions of 200- to 400-year-old post oaks, trees predating the birth of our nation and which had already lived for a century or more at the time of Washington Irving's visit to Indian Territory. [2] The area has also been an important site of oil extraction for over 80 years. Considerable urban growth and expansion throughout this region will continue to impact wildlife habitat resources in the future. This region contains the cities of Fort Worth, Granbury and Denton, although Denton lies on the border with the Eastern Cross Timbers. . County . Discuss tips with your expert, if appropriate, on how to rephrase some technical explanations and make them easier to understand. The Western Cross Timbers country presents a landscape unexpected in West Texas. 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? Copyright 2012 - 2023 Huseby, LLC. 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. They merely e-mail each other. Discovery Litigation Services is skilled in Cross Timbers depositions and court reporting. Direct link to braalt02's post Yes. 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. 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. It is important to stay calm, because only then can you stay in control. ", 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. 10. E-Newsletter Archive. We'll send you a couple of emails per month, filled with fascinating history facts that you can share with your friends. It will be easy to get angry and frustrated with an evasive, non-responsive witness. 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 you're seeing this message, it means we're having trouble loading external resources on our website. For all yes or no questions, framing is key for both the expert and the cross-examiner. 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. Direct link to I love Isabelle's post Mechanical weathering is , Posted 6 months ago. Weathering occurs when water breaks down rocks and soil to create sediment. 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 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. People spontaneously write e-mails without hesitation and, more importantly, without reflection or thinking. If the last area of questioning finishes off the experts credibility, you have one. Q: And that-to use your words-concerned you, isnt that true? Put the expert into a box. These experts may be susceptible to being put into a box for purposes of cross-examination. with let's say a sm, Posted 3 months ago. 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. https://www.tshaonline.org, https://www.tshaonline.org/handbook/entries/cross-timbers. This is one of the only chances opposing counsel will have to directly poke holes in your case by attacking the credibility of your experts testimony. How acidic is Acid Rain and how does it happen. [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. A broader, southern extension of the Grand Prairie, found only in Texas; it is underlain by limestone rather than sandstone, and serves as a physiological and vegetational transition to the Edwards Plateau, which it borders to the south. Urban sprawl and developments have rapidly extended into the sub-region as the human population to increased in the region. 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 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 . Toward the south the Eastern Cross Timbers belt spans the ninety-seventh meridian from the Red River to the Brazos River. accessed May 01, 2023, 26 Downer Avenue Campbelltown SA 5074; (Diggs et. If you doubt that, go back and look over the last cross examinations you have handled. A: Yes. Direct link to DRAKEB's post I don't know. Soils at the surface, consequently, support the growth of plants adapted to higher alkalinity, such as live oak and juniper. Cross Examination Rules, Strategies and Traps to Avoid. Login (855) 847-0999 calendar@huseby.com If he or she then tries to testify to additional opinions at trial and you had expressly confirmed at the deposition that there were no other such opinions, the additional opinions later offered might be subject to exclusion. The Eastern (or Lower) Cross Timbers, a narrow band of blackjack and post oak, separates the region of Black Prairies on the east from the Grand Prairies on the west. First, consider whether the case is likely to proceed to trial. . 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/. Direct link to Mahiro's post I have a river in my back, Posted 2 months ago. Posted on Nov 14, 2016. Take the lead on how to engage the judge. 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. 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. It is very important for you to generally remain the noble person who is confronting the expert. I have a river in my backyard and when the rainwater evaporates i can see the dirt that got eaten at by the rain :^. Discovery Litigation will cover your Cross Timbers deposition. S. Fort Worth, Texas 76118. 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. 5' #hj5 ob2Q9{Kv/r.:QyH#g& _6uf` ,M'vZS \\ \hVL`B`fBulO6&S@[q{r:kq?/Kx UudoFlC-x6|vwbvbmjT|OOQx yJ-C. We understand the need to use the highest quality reporter for you. For example, you may want to wait to use some documents at trial to surprise a witness and not allow him or her time to think of an explanation for a document. 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. Exposed sandstone rocks and boulders dominate landscape features in many areas. Talk with the expert, if truthful and appropriate, about not framing answers in a way to appears partial to one side or the other. This was an important influence on early settlement as underground water was available from shallow wells dug into the Trinity sands. [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. It was also a formidable obstacle to travelers because of the density of growth. 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. One of the best ways to get judges to interact with the experts testimony is to make his or her methodology both easy to understand and easy to use. Ensure that you have covered all bases for each opinion by asking catchall questions such as Are there any other bases for this opinion that you have not already mentioned? Make sure you keep asking that question until the answer is a definitive no. Then, move on. [6] More specifically, the Cross Timbers fall into Level II Ecoregion 9.4, the smaller South Central Semi-Arid Plains. c. Effective Use of Evidence/Documents in Examination. 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 the expert continues to offer an evasive non-answer, you must redirect the expert to your question and make him or her answer it. 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. If someone is going to argue, it should be the expert. Schedule your Missouri/court Reporters Cross Timbers/ deposition today! In most jurisdictions, re-direct is limited to matters that were covered on cross. If you are careful about not opening up subjects that you know are likely troublesome, you may be able to prevent questions on those subjects during re-direct. 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 almost doesnt matter what the witnesss response is. 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. Fort Worth Prairie - In Northcentral Texas, the Fort Worth Prairie vegetative sub-region is located between the East and West Cross Timbers sub-regions, extending from western Cooke and eastern Montague counties on the north, southward to northern Edwards Plateau and includes portions of Denton, Wise, Tarrant, Parker, Johnson, and Hood counties. This sub-region has a complex geologic history, resulting in a variety of soil types, terrain features, and vegetative plant communities. Nearly all surface rocks of the North Central Texas were deposited during the Cretaceous Period (145-65 millions years ago). 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. Be persistent, but polite. 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. 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. Good experts have probably spent several times as many hours on cross in a courtroom as you have. 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. See additional disclaimers, MISSOURI, ILLINOIS, KANSAS, OKLAHOMA, & NEBRASKA FAMILY LAW ATTORNEYS, Charitable Giving and Community Involvement. Comanches raided east of the Cross Timbers in the early years, and the Wichitas and others used the wood in the Cross Timbers. He lied when he wrote it? 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. 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 not, consider whether that question should be dropped or recast. 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. 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 Cross Timbers divide the eastern forests and the southern plains and became the boundary between eastern Indian tribes and the Plains tribes. Remind your witness that the objective of a cross-examination is not to pick a fight with the attorney, but an opportunity for the witness to stick to their guns and present an even stronger case to the jury for your client. 1999). 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. 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. Cross Timbers. Today, few large tracts of undisturbed woodlands remain in the East Cross Timbers which is perhaps the most fragmented vegetative region in Texas. You also want to avoid being surprised. Since the region has a subhumid climate, its natural vegetation would ordinarily be grass; its scrubby tree growth results from edaphic features. |Kfpss Published by the Texas State Historical Association. Habitat for white-tailed deer, Rio Grande turkey, bobwhite quail, mourning doves, fox squirrels, rabbits and a variety of nongame wildlife species is found here. You must establish control early by making the expert answer your question. The Underwood is so matted in many places with grapevines, green-briars, etc., as to form almost impenetrable "roughs," which serve as hiding-places for wild beasts, as well as wild Indians; and would, in savage warfare, prove almost as formidable as the hammocks of Florida. What Are the Benefits of Having an Estate Plan? In pioneer times the band of timber was a famous landmark. About CRT. All rights reserved. Reveal number. If you're behind a web filter, please make sure that the domains *.kastatic.org and *.kasandbox.org are unblocked.

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