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. Post oak-blackjack oak woodlands characterize much of the West Cross Timbers. In this situation, you will want to understand what the witness will say and establish points that you want to focus on in the deposition by using wide-ranging and more open-ended questions. There is nothing gained by appearing to become angry and frustrated by the experts unwillingness to concede points that she should obviously concede. [7] In southern Oklahoma, the Cross Timbers are located on the very edge of the Great Plains, as they border directly parts of Level I Ecoregion 8.0, the Eastern Temperate Forests; elsewhere, the Cross Timbers are separated slightly from the Eastern Temperate Forests. 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. [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. 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. The Cross Timbers bands made travel difficult for settlers, yet the ecosystem provided for their basic needs. In some places, however, the oaks are of considerable size, and able to withstand the conflagrations. Cross Timbers | The Encyclopedia of Oklahoma History and Culture Often, an expert such as a treating doctor who is not an outright advocate for the other side will concede points when appropriate. You must be clear about the purpose of your deposition. 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. See additional disclaimers, MISSOURI, ILLINOIS, KANSAS, OKLAHOMA, & NEBRASKA FAMILY LAW ATTORNEYS, Charitable Giving and Community Involvement. 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. Good experts have probably spent several times as many hours on cross in a courtroom as you have. In our business, there is no margin for error. Beyond that, with respect to each opinion the expert has, make sure you ask the expert to exhaustively identify all the bases for each. Military divorces are handled, For many people, the holidays are a time of joy and happiness where the traditional obligations of work and school are put on hold, and, Aspatore Books from Thomson Reuters Westlaw. II. 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. The . The point is that you must have an outline and a strategy for your deposition of an expert. Farm and ranch size is relatively large, making accomplishment of land management strategies for wildlife and habitat both productive and feasible. You may be able to find information in the treatise or from one of the authors that contradicts the experts opinions. endstream endobj 2266 0 obj <>stream [4] The Cross Timbers are contained within the WWF central forest-grasslands transition ecoregion. (Was that what you meant by 'Which one is more comman'). This was an important influence on early settlement as underground water was available from shallow wells dug into the Trinity sands. Part of the difference in the Cross Timbers region and the surrounding regions west (drier) and east (wetter) has to do with the dry line which separates humid air from the Gulf of Mexico from the dry air of the Llano Estacado, the Texas Panhandle, and the High Plains. 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. The towns of Sand Springs, Sapulpa, Ada, and Shawnee, Oklahoma fall within this large area; Bartlesville and Okmulgee lie on the eastern edge. "[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]. Highways also cross the area.[2][3]. About 17 million acres are represented by this region of alternating bands of wooded habitat scattered throughout a mostly prairie region. cross timber: [noun] a strip of woodland chiefly of oaks stretching across grassland especially in Texas. Soils throughout the region are not uniform. Extensive open grasslands and brushy rangelands occur in the West Cross Timbers sub-region. Cross Timbers Royalty Trust (CRT) is a micro-cap, and a tiny one at thatit has a market capitalization of just $145 million. Map | The Ancient Cross Timbers Consortium This sub-region has a complex geologic history, resulting in a variety of soil types, terrain features, and vegetative plant communities. |-!U`&w. Kjj(-(pJ|wRrAG NA{A$3HL1Q8%_  Court Reporting Missouri/court Reporters Cross Timbers/ The Cross Timbers: The Ancient Forest at America's Crossroads Kara M. Burgos, Andrew B Hebl, & Eric J. Ryberg, 101: Deposition Techniques: Get Your Ducks in a Row, Wisconsin Lawyer, (September 1, 2013), http://www.wisbar.org/newspublications/wisconsinlawyer/pages/article.aspx?Volume=86&Issue=7&ArticleID=11015/. 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/. Crow Holdings has submitted to the town of Flower Mound a site plan proposal for the Cross Timbers Business Park, a 10-building warehouse park in the northwest corner of FM 1171 and Hwy 377. Dyksterhuis (1948) described the Western Cross Timbers as an area "extending 150 miles south from the northern limits near the Red River, curving westward at the southern extremity. You are paying a significant amount for the deposition, so get your moneys worth. 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. [2], No major metropolitan areas lie wholly within the Cross Timbers, although roughly the western half of the Dallas-Fort Worth Metroplex does, including the cities of Fort Worth, Denton, Arlington, and Weatherford. 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. Brainstorm with your expert better ways to present this information that will keep the judge interested in your experts testimony. Throughout its current range, the Cross Timbers forest ecosystem is vulnerable to land-use change. Before taking an expert's deposition, the parties should have completed fact discovery-interrogatories answered, documents obtained, lay witnesses deposed. Some organizations and maps refer to the Cross Timbers ecoregion as the Central Oklahoma/Texas Plains. Topographically, much of the Western Cross Timbers is characterized by rough features, in contrast to the smooth outlines of the lands both to the east and to the west. Many trial judges create their own rules of courtroom behavior. Q: And that-to use your words-concerned you, isnt that true? For example, if a witness may not be at trial, you do not want to have that witness give responses adverse to your client; you should then be wary of open-ended questions (e.g., what happened next?). 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. Its market capitalization is minuscule, but its dividend is quite large. It is bordered on the east by the Blackland Prairie Ecological Region, the west by the Rolling Plains Ecological Region, and extends south and southwestward to the Llano Basin and Edwards Plateau Ecological Region in central Texas. The Cross Timbers of Texas is two long and narrow strips of forest region that extend parallel to each other from Oklahoma southward to Central Texas between the ninety-sixth and ninety-ninth meridians and form a marked contrast to the prairies of the state. Two fragments adjacent to If the experts answers appear to defeat the credibility challenge posed by your questions, then you have lost and the expert has won. Today, few large tracts of undisturbed woodlands remain in the East Cross Timbers which is perhaps the most fragmented vegetative region in Texas. The region features a limestone substrate as opposed to sandstone, and has greater topographical relief and denser and different vegetation than other parts of the Cross Timbers. 200 - 300 year old Post Oaks can be found at: . The location of the East and West Cross Timbers was well known by these early travelers who used them as points of reference for travel. Talk with your witness, if truthful and appropriate, about avoiding absolutes. This means making statements like in all cases or every time. This way, the witness does not close to the door to a certain line of questioning and open himself up to impeachment later. Failing to listen to the answers you are getting is the next most common pitfall. Cross Timbers Ecosystem | Cross Timbers Urban Forestry Council 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. All rights reserved. deposition, such as using exhibits and cross-examination. A: Yes. The region has been important chiefly for its mineral resources. This way, your witness does not call out uncertain answers based on a pressure to perform. Rainfall is highly variable in this region, averaging about 25 inches in the western reaches to 35 inches in the east. Be persistent. The trees served as a testament to the harshness of the environment. Acid rain is about 100 times less acidic than Coca-Cola. 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. Witnesses do not talk to each other anymore. [2] I-35 crosses this region north to south. The expert may provide an even more perfect setup for your next question than your question did. 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. 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. Much of the land in this region is also used for livestock ranching for cattle, sheep, and goats. West Cross Timbers - In Northcentral Texas, the West Cross Timbers vegetative sub-region, located immediately west of the Fort Worth Prairie and north of the Lampasas Cut Plain, extends from the Red River in Montague and Cooke counties south and southwestward to the Lampasas Cut Plain and west to the Rolling Plains. He stated, "The growth of timber is principally small gnarled, post oaks and black jacks, and in many places the traveler will find an almost impenetrable undergrowth of briers and other thorny bushes. Posted 6 months ago. Deny that he wrote the document? Surprisingly, however, these trees conceal their age very well. This can only be accomplished by addressing the credentials, assumptions and opinions that the expert has testified to that you know you can demonstrate are not worthy of the jurys belief. 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. They merely e-mail each other. Hundreds of e-mails. The Cross Timbers and Prairies Ecological Region of Texas encompasses approximately 26,000 square miles in north and central Texas and is the primary ecological region of Northcentral Texas. In pioneer times the band of timber was a famous landmark. How acidic is Acid Rain and how does it happen. Ecoregion 5 - The Cross Timbers and Prairies. Nice! Our court reporters, videographers, and team members have been educated on Huseby's in-person deposition guidelines. It passes through northwestern Grayson County, eastern Cooke, Denton and Tarrant counties, central Johnson County, western Hill County, and northern McClennan County. Sometimes experts are advocates for the parties that have retained them. Development plans. The region is well adapted for truck farming. First, do not argue with the witness. 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. Direct link to Mahiro's post I have a river in my back, Posted 2 months ago. A: Yes. HVpTWg6o@ <6dw#H1Vwl&$ )F((h-BP#P*"m%V 8Nqs~9.hdF8l#h!> 6DLylK]7j#qMDDnPA5 _}hqiKIH|xc-u^4{|W:rI@ .Vo@ *{v"Y1p\"iyR~*v5Jzvc%Sy,">J0z)-W(Q\XXP*Q33K4tay|$B1R*0LZqi)S%BQ]tQ?u\.F0 )wTDFG'QO-pmlI4-S,\9,D# ZXuiB3C514q$hDl}4;Z2+9>g@V $!xt El-![OvA6`s*hIa]! Obviously, helpful opinions given by an opposing expert will be more valuable than if those opinions are coming from your own expert. What to do when a Witness is Being Evasive of Defiant. In 1854, W. B. Parker who traveled with a survey party of the United States Government to locate and survey lands for Indian reservations in north Texas noted, "The timber is a short, stunted oak, not growing in a continuous forest, but interspersed with open glades, plateaus, and vistas of prairie scenery, which give a very picturesque and pleasing variety:" On crossing the Upper (Western) Cross Timbers west of present day Gainesville in Cooke County, Parker stated, "Below, stretching as far as the eye could reach, lay the apparently interminable forest of the Cross Timbers, like a barrier, on passing which we were to be shut out from civilization, its joys and cares, for many, many weeks.". 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. 26 Downer Avenue Campbelltown SA 5074; Fax: 817-272-5977. The presettlement Cross Timbers are believed to have covered approximately 28,000 square miles (7,250,000 hectares), extending from central Texas across . Don, Penny and the staff are awesome ate what they do. hb```e``c`230 P9CLlll?9qZHx*"9p1qrxqmG\B/_8:x89vsp\==c/vq\\wUz2Ev={mnmwoIxv;D@YY .l @dp&0f X;"@ More likely, confronted with the e-mails memorializing of the witnesss contemporaneous statement, the witness is bludgeoned into an admission of yes. Your questioning style may be open-ended like a direct examination, narrow and controlling like a cross-examination, or a combination of the two. The movement of water can create and modify features on Earths surface. Eliciting Deposition Testimony: Real-World Application of Techniques. Beyond discovering what happened, be clear on what two or three points you want to establish through a witnesss testimony. 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. See for yourself why so many call us their reporting company. Schedule your Cross Timbers deposition today! People spontaneously write e-mails without hesitation and, more importantly, without reflection or thinking. We understand you may have questions about attending depositions in-person during COVID and we can help you tailor your deposition experience to your comfort level. Cross Timbers Royalty Trust raises dividend by 8% to $0.161 Cross Examination Rules, Strategies and Traps to Avoid. 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. We understand the need to use the highest quality reporter for you. I have a river in my backyard and when the rainwater evaporates i can see the dirt that got eaten at by the rain :^. [2] In turn, the Cross Timbers are themselves subdivided into nine Level IV Ecoregions: This is a wide belt of land stretching from south-central Oklahoma into southeastern Kansas and is the only part of the Cross Timbers that extends into Kansas. 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. 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. 0 2022 by Stange Law Firm, PC. Cross Timbers' acquisition strategy has given it a sizeable portfolio of drilling prospects. 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.