Constructive Cross-Examination Jan and Susan Design Constructive Cross-Examination Jan and Susan Design

Constructive Cross for Depositions and Trials

Runtime: 3:11:22

Performed by: Roger Dodd, Matthew A. Dodd and Patricia C. Kuendig / Co-produced by Kimberly McCoggle

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

  • Comparing and Contrasting Cross for Trial and for Depositions

  • Developing Chapters and Sequence of Chapters

  • Imagining and Visualizing Cross Chapters Including Word Selection

  • Prepare, Listen, and Practice

  • Comparing Different Generations of Cross-Examiners and Male and Female Lawyers

  • Quoting Bad Language on Cross

  • Negative Imaging

  • Teaching at Depositions to Drive Settlements

  • “I Don’t Know” Witnesses and How to Turn Them to Our Side

  • How to Build “Lock-In” Chapters

  • The Difference Between Teaching and Advocating

  • Documents at Deposition Cross

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Constructive Cross-Examination Jan and Susan Design Constructive Cross-Examination Jan and Susan Design

Cross-Examination of an Investigating Officer

Runtime: 3:16:01

Performed by: Joseph Low
With commentary and analysis by Roger Dodd

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

  • Cross-Examination of an Investigating Officer

  • Bifurcated trial for Liability and for Damages

  • Cross reacting to the Demeanor of Witness

  • Chapters on Body Language

  • Explaining ‘Why’ to the Jury Without Using the ‘Why?’-Phrased Question

  • Singling Out Jurors for Specific Chapters

  • Avoiding Emotional Over-Selling

  • How to Avoid Tone of Questions That Evoke Fear or Judgment in Jurors

  • Low-Tech Demonstratives

  • Pretrial Drafts

  • Credibility Cross

  • Reflecting the Judge’s Degree of Care

  • Grey Areas: Whether and When to Do It

  • Asking Questions the Jury Wants to Ask

  • Preparation of Cross

  • Cross of Suppression of Information

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Expert Witness Cross-Examination Jan and Susan Design Expert Witness Cross-Examination Jan and Susan Design

Cross-Examination of a Medical Expert (Dr. Amos)

Runtime: 3:16:45

Performed by: Roger Dodd & Sean Claggett
With commentary and analysis of Sean Claggett’s cross-examination.

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

  • Cross of Opposing Doctor Expert

  • Expert Impeachments from Websites

  • Cross of the Expert “I Don’t Know” Witness

  • Spontaneous Loops of the “I Don’t Know” Expert Witness

  • Linguistics

  • Listening for Spontaneous Loop Opportunities

  • Examples of “Don’t Start” Questions

  • Constructive Cross-Examination

  • Conclusions and Losing Control

  • How Experts Hide Behind Conclusions

  • “Why?” Questions Inviting Danger

  • Demeanor of Cross-Examination

  • Cross of Expert Who Tries to Use Ethics Justifications

  • “What Not Done” Chapters

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Constructive Cross-Examination Jan and Susan Design Constructive Cross-Examination Jan and Susan Design

Cross-Examination in Medical Malpractice Case

Runtime: 3:32:01

Performed by: Roger Dodd & Lloyd Bell
With commentary and analysis of Lloyd Bell’s cross-examination.

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

  • Calling Opposing Party’s Witnesses for Cross-Examination

  • Calling Opposing Party’s Witness for Constructive Cross-Examination

  • Delivering Testimony in the Form of Chapters and Chapter Bundles

  • Using Demonstrative Evidence in Cross-Examination

  • Performing Serial Impeachments

  • Making Impeachments More Memorable

  • Listening for Spontaneous Loop Opportunities and Recency to Close a Cross-Examination

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Jan and Susan Design Jan and Susan Design

Cross-Examination of an Orthopedist: Dr. Clement Jones (Episode 1 of 2)

Runtime: 3:56:23

Performed by: Brian Panish & Spencer Lucas
With commentary and analysis of Brian Panish’s cross-examination.

Episode 1—Methods & Techniques Discussed: (not limited to those listed)

  • Bus Reconstructionist and Bio-Mechanical Expert

  • Bias, Interest, and Motive

  • Cross-Examination of Failure to Produce

  • Expert Fees and Discount

  • Use of Deposition for Impeachment

  • Opening Sequence of Cross on Expert

  • Common Spontaneous Loops for Experts

  • Cross of Expert CV

  • Access to Witness’s Notes While on the Stand Testifying

  • How Volume of Cross-Examiner’s Voice Impacts Dramatic Moments

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Expert Witness Cross-Examination Jan and Susan Design Expert Witness Cross-Examination Jan and Susan Design

Cross-Examination of an Orthopedist: Dr. Clement Jones (Episode 2 of 2)

Runtime: 3:56:23

Performed by: Brian Panish & Spencer Lucas
With commentary and analysis of Brian Panish’s cross-examination.

Episode 2—Methods & Techniques Discussed: (not limited to those listed)

  • Primacy and Recency

  • Reversal

  • Using Witness’s Titles

  • Relying on the Three Rules

  • Confronting Witness with Retractions

  • Confronting Witnesses with Lies and Intentions

  • Overcoming Obstructive Objections

  • Examples of Ways to Control an Evasive Expert Witness

  • The Effective Use of Constructive Cross

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