Constructive Cross for Depositions and Trials


Performed by: Matthew A. Dodd and Patricia C. Kuendig
With commentary and analysis by Roger J. Dodd.

Synopsis:
Using trial and deposition examples, this program demonstrates how to constructively prove your case through opposing witnesses and their experts on cross-examination. It begins with depositions that don’t simply “discover” facts but seek and secure verbal admissions. By doing so, opposing counsel is forced to choose between not calling their witnesses—leaving your evidence unchallenged—or proceeding despite knowing you already have the ammunition.

Runtime: 3:11:22

 

Methods & Techniques Discussed: (not limited to those listed)

  • Constructive cross principles

  • Comparing and contrasting deposition vs. trial cross

  • Developing and sequencing chapters

  • Word selection and visualization

  • Preparation, listening, and practice

  • Teaching at depositions to drive settlements

  • Handling “I don’t know” witnesses

  • Lock-in chapters and negative imaging

  • Teaching vs. advocating

  • Using documents effectively during cross

 
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Cross-Examination Training by Dan Ambrose