To look or not to look at the target witness - it's a matter of personal style.

The 'real time' risk assessment that governs how you conduct your cross-examination:  it can be OK to ask questions to which you do not know the answer.  It can also be OK to ask open questions.

The thrill of the spontaneous 'perfect' question which is not spontaneous at all.

Be sure to keep something good for the finish: write it out.

Rehearse with your witnesses as to when they are to answer you opponent with 'Would you like me to explain'.


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