The Eastern (or Lower) Cross Timbers, a narrow band of blackjack and . Current Projects. Consequently, plant communities change dramatically within short distances resulting in different land use potential for livestock grazing, farming, wildlife management, or other uses. 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. 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]! Beyond that, with respect to each opinion the expert has, make sure you ask the expert to exhaustively identify all the bases for each. they make everyone who enters the door feel like family. This region was called the Upper Timbers by early travelers due to its higher elevation. Comanches raided east of the Cross Timbers in the early years, and the Wichitas and others used the wood in the Cross Timbers. Q: When you wrote in that e-mail you were concerned about meeting the production deadline under the contract, that was a true statement when you wrote it, was it not? That can lead to a lengthy, tedious cross that does not capture the judges attention. If the case goes to trial, usually only a very small part of the deposition is ever used. 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. If you're seeing this message, it means we're having trouble loading external resources on our website. because the big rock has more volume than the small rock, the water has more atoms to break down for the big rock to be broken. [6] More specifically, the Cross Timbers fall into Level II Ecoregion 9.4, the smaller South Central Semi-Arid Plains. Witnesses do not talk to each other anymore. Coca-Cola is not strong enough to dissolve skin. Cross Timbers' acquisition strategy has given it a sizeable portfolio of drilling prospects. 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. 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. Cross Timbers APEX Accelerator at The UTA Research institute. This sub-region has a complex geologic history, resulting in a variety of soil types, terrain features, and vegetative plant communities. Considerable urban growth and expansion throughout this region will continue to impact wildlife habitat resources in the future. [2], An extension in two branches of the Cross Timbers into southwestern Oklahoma, this area features reduced tree density and height, but also small forests dominated by sugar maple, bur oak, and live oak in deeper river canyons. 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. Accordingly, use your documents to weave your testimony on cross-examination. In Cross Timbers, we will need to find a location to host your deposition. If the last area of questioning finishes off the experts credibility, you have one. These landscape changes will have long lasting consequences for wildlife and habitat resources in this sub-region. Considerable farming and livestock grazing operations were initiated by early settlers in areas of sufficient soil depth in this sub-region. cross timbers deposition 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 . Review your understanding of weathering and erosion in this free article aligned to NGSS standards. Plaintiff Ken Burger ("Burger") is an Ohio citizen who resides in Cincinnati, Ohio. Counties found in the sub-region include parts of Somervell, Erath, Hamilton, Comanche, Brown, Mills, Bosque, Hill, and McLennan counties. What Distinguishes a Military Divorce From Other Types of Divorces? hb```e``c`230 P9CLlll?9qZHx*"9p1qrxqmG\B/_8:x89vsp\==c/vq\\wUz2Ev={mnmwoIxv;D@YY .l @dp&0f X;"@ B. Much of the land in this region is also used for livestock ranching for cattle, sheep, and goats. endstream endobj 2267 0 obj <>stream [3] Today, land use is a mixture of rangeland, pastures, and farmland. You may be able to find information in the treatise or from one of the authors that contradicts the experts opinions. Two fragments adjacent to endstream endobj 2265 0 obj <>stream Texas Farm and Ranch Land Conservation Program, Wildlife Management in North Central Texas. You would cross-examine the witness in this type of deposition as you would at trial. 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. PDF Weathering, Erosion, and Deposition in the Texas Ecoregions - Weebly Every person works hard to collect different property, investments, and assets throughout their life. MKulu#9315a;3CIc(@F.42D$90IdqD-1)#^ xx 6y|-&oO RFl_KnOUP)X}Plgj0JX`m#ruo%jL'}{X q1'vQ ;O=s9kHxaKh0$RWq uo8/{E'&KJpi']}q{LG? This happens through weathering, erosion, and deposition. Sure Dividend has compiled a database of 84 . Discovery Litigation Services is skilled in Missouri/court Reporters Cross Timbers/ depositions and court reporting. They merely e-mail each other. accessed May 01, 2023, "F)YA`:KAls!G>;~ZO Ecoregion 5 - The Cross Timbers and Prairies. Direct link to Levi's post Can acid rain dissolve hu, Posted 6 months ago. Deciding to end your marriage is never simple, especially when you know how difficult the process can be. Whether you need videographer services, interpreter services, or something even more unique, we have the personnel and service culture to make your deposition as seamless as possible. 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. No matter how many times an expert has testified at trial, being grilled during cross-examination is always incredibly stressful. V. CPLR 3113 [c] examination and cross-examination of deponents shall proceed as permitted in the trial of the actions in open court A. About CRT. Or perhaps this witness will just be combative-either way, there are ways to control such witnesses effectively. PDF Weathering, Erosion, and Deposition: Trans Pecos/Chihuahuan Desert This way, it makes clear that your witness is not evading a difficult question, but is rather answering in the most accurate way possible. 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. About Cross Timbers - Cross Timbers Procurement Center - UT Arlington First, consider whether the case is likely to proceed to trial. Ask open-ended questions that will allow the expert to elaborate on the most important points of testimony. Cross Timbers - Wikipedia The easiest way to control a witness is through the use of exhibits. Post oak-blackjack oak woodlands characterize much of the West Cross Timbers. S. Fort Worth, Texas 76118. 2022 by Stange Law Firm, PC. Direct link to 54225's post So basically if I added w, Posted 21 days ago. {}~ysZ=*dv-v^AhYAuuBWy=(G0Y7eJd#YR2L$U4EB/t0 After the introduction of domestic livestock, farming operations, and control of wildfires, the landscape of much of the Lampasas Cut Plain changed. This is significant, since bias is a valid grounds for disqualifying an expert witness. Some exposed surface formations in the western part of the West Cross Timbers date from the 300-million-year-old Pennsylvanian Period. Some rules may affect what you are allowed to do on cross examination. Overgrazing by livestock and elimination of naturally occurring fire also reduced native grass cover and allowed the invasion of other less desirable annual grasses and forbs. The pH of acid-impacted rain is generally below 4.5 on the pH scale. Website and Maintenance by Appeal Design, Court Reporting Cross Timbers, Missouri 65634. Your ability to smoothly demonstrate that you have a true mastery of the subject that you are discussing with the expert, while satisfying to you, is of no benefit to the judge. Another strategy to handle this type of question is to say in some circumstances if that is the case. Sustainability | Free Full-Text | Sustaining Cross-Timbers Forest Beginning in the eastern half of Cooke County, it extends southward through the eastern parts of Denton, Tarrant, and Johnson counties and the western parts of Grayson, Dallas, Ellis, and Hill counties. Judges hate repetition anyway because they are tired enough of the trial and dont want to watch the same hand played again. He lied when he wrote it? No towns of any size lie within this area, although Possum Kingdom Lake and State Park do;[8] the region is crossed by US 180 and Texas State Highway 16. 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. [5] The prairie portions are chiefly tallgrass on finer, dry soils. When you have prepared for hours or days to destroy an opposing expert, you become captivated by how powerful your carefully crafted outline is. Deny that he wrote the document? Lampasas Cut Plain - In Northcentral Texas, the Lampasas Cut Plain vegetative sub-region lies south and southwest of the East and West Cross Timbers and Fort Worth Prairie, extending to the upper reaches of the Edwards Plateau. 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. [2] It includes a small part of Love County, Oklahoma (the only part of this region outside of Texas) and passes south through western Cooke County, eastern Wise County, and western Denton, Tarrant, and Johnson counties, and also includes parts of Parker, Erath, Hood, Somervell, Hill, and McClennan counties. The expert may provide an even more perfect setup for your next question than your question did. In some jurisdictions, cross is strictly limited to the scope of direct. 2261 0 obj <> endobj The Western (or Upper) Cross Timbers comprises an irregularly bounded wooded region in north central Texas, extending in a generally southward direction through Montague, Wise, Jack, Parker, Hood, Erath, and Comanche counties. For all yes or no questions, framing is key for both the expert and the cross-examiner. 2272 0 obj <>/Filter/FlateDecode/ID[]/Index[2261 27]/Info 2260 0 R/Length 69/Prev 462257/Root 2262 0 R/Size 2288/Type/XRef/W[1 2 1]>>stream 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. The other party only gets to cross examine the witness. All of Hamilton and Coryell counties, large parts of Bell, Lampasas, Mills, Erath, and Bosque counties, and smaller parts of Williamson, Burnet, Brown, Comanche, Hood, Somervell, and McClennan counties, including the towns of Killeen, Copperas Cove, and Lampasas as well as the Fort Hood Army base, fall within this region. The region has been important chiefly for its mineral resources. Schedule your Missouri/court Reporters Cross Timbers/ deposition today! In pioneer times the band of timber was a famous landmark. 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. Remind your expert not to get defensive if they feel attacked by a line of questioning. 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. (see LOWER PLAINS.). Anderson, Roger C., James S Fralish, Jerry M. Baskin (eds.). [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. The forgetful witness may be one of the most frequently encountered types of difficult witnesses, and it is important that you learn how to deal with the all-to- frequent testimony of I dont remember, or I cant recall, or That was a long time ago, and I cant say for sure. First, if you are cross examining the witness who doesnt remember, be especially careful to limit your questions as much as possible to elicit only yes or no responses-any place where the witness can add in unnecessary verbiage will likely not be good for your case. 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. Save the Ultimate Point for Summation. Beyond discovering what happened, be clear on what two or three points you want to establish through a witnesss testimony. Every penny counts! Austin: University of Texas Press, United States Environmental Protection Agency, "Ecological Regions of North America Level I", "Ecological Regions of North America Level I-II", "Descriptions of the Level IV Ecoregions of Texas", "TPWD: An Analysis of Texas Waterways (PWD RP T-3200 1047) Brazos River", "Brazos River Canyonlands The Brazos River", Texas counties map showing the ecoregion; similar to the above map. 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. 26 Downer Avenue Campbelltown SA 5074; If you're behind a web filter, please make sure that the domains *.kastatic.org and *.kasandbox.org are unblocked. you may want to treat the deposition as a cross-examination . Acid rain is about 100 times less acidic than Coca-Cola. There are other considerations that will guide your questioning style. 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. Be sure to discuss with your expert instances where I dont know is NOT an acceptable answer, such as when the question directly relates to a basis or methodology of your experts opinion. Q: In fact, you anticipated that the contract production requirements were not met, isnt that true? ", In 1840, Col. lB)Onw@HO l [2][4], In Oklahoma, this belt of woodland covers all of Marshall County and parts of Love, Carter, Johnston, and Bryan counties, but in Texas, this region exists as a long, very narrow strip of dense forest stretching from the Red River to just north of Waco, Texas. 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. 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. So basically if I added water to rock paper scissors, I would win each of them? 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. Signup today for our free newsletter, Especially Texan. [1] Made up of a mix of prairie, savanna, and woodland,[2][3] it forms part of the boundary between the more heavily forested eastern country and the almost treeless Great Plains,[2][3][4] and also marks the western habitat limit of many mammals and insects. Parks and Recreation. 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. Posted on Nov 14, 2016. WHAT DOES AN IN-PERSON DEPOSITION LOOK LIKE? Sometimes, based on a desire to please the attorney and the court, experts may get ushered into answering a line of questioning outside the scope of their expertise. Private message. 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. If you are not ready to return to in-person depositions, you can continue to use alternative ways to remotely attend depositions and access case files effectively. You can continue to count on us to do our best to serve you with the highest levels of service and support for all of your court reporting needs, whether you choose to continue remotely or move back to in-person across the country. Language links are at the top of the page across from the title. Surprisingly, however, these trees conceal their age very well. In essence, you are making the judge the expert. Exactly What Are the Cross Timbers? - LakeTexoma.com The towns of Sand Springs, Sapulpa, Ada, and Shawnee, Oklahoma fall within this large area; Bartlesville and Okmulgee lie on the eastern edge. This happens through weathering, erosion, and deposition. Direct link to braalt02's post Yes. Be persistent, but polite. 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. Yes. The Cross Timbers are defined by the United States Environmental Protection Agency as Ecoregion 29, a Level III ecoregion. We are a community-supported, non-profit organization and we humbly ask for your support because the careful and accurate recording of our history has never been more important. Asking a question more than once is frequently the mistake that destroys much of the impact of the experts first great answer, before he had the opportunity to consider how to better position that answer. Lay them out like a long mosaic and weave them back together as you tell your story through cross-examination. The Cross Timbers divide the eastern forests and the southern plains and became the boundary between eastern Indian tribes and the Plains tribes. They stretch from southeast Kansas through central Oklahoma to just north of Waco, Texas. Map | The Ancient Cross Timbers Consortium PDF Texas Conservation Action Plan These experts may be susceptible to being put into a box for purposes of cross-examination. Call Discovery at (855) 847-0999. Direct link to Mark's post Acid rain is about 100 ti, Posted 2 months ago. This way, your witness does not call out uncertain answers based on a pressure to perform. Also, when it comes to the judges perception, you want to continue to make sure you are the one who looks credible and forthcoming. [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. How you ask questions at a deposition depends upon your purpose in that deposition. This field is for validation purposes and should be left unchanged. any personal information to the agency. Don, Penny and the staff are awesome ate what they do. For example, by allowing them to describe their impressions and reactions as they started going through their damages calculations or as they read the opposing experts report, it allows the judge to understand how the expert formed their final conclusions. 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. Cross examining a witness who refuses to be led can be a difficult task. All rights reserved. Q: You knew there had been a delay in the manufacturing process, didnt you? On June 19, 2014, Burger initially filed a Complaint in the United States District Court of the Southern District of Ohio. PDF Structure, Composition, and Regeneration of Cross Timbers Forest hbbd``b`^$@$b8`v @"#"O The cross of a tough expert should seldom take more than one quarter of the time that was taken on direct. In most jurisdictions, re-direct is limited to matters that were covered on cross. Q: And that was the concern you wrote about in your e-mail, was it not, sir? 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. What evidence of weathering erosion and deposition exists in . Schedule your Cross Timbers deposition today! Retained experts are notoriously difficult to control, particularly for a new lawyer. Trisha M. Rich, Effectively Examining the Difficult Witness, Trying Your First Case: A Practitioners Guide, (April 2014), http://www.americanbar.org/content/dam/aba/administrative/litigation/materials/2014_sac/2014_sac/trying_your_first_case.authcheckdam.pdf/. You must be clear about the purpose of your deposition. The best way to prepare your expert for facing difficult questions on cross is to practice them with your experts, if appropriate. The Cross-Timbers region of the United States, situated in the southern Great Plains along the western edge of the eastern deciduous forest, was historically Quercus-dominated open forest interspersed with tallgrass prairie and shrubs communities. The objective of cross examination of an expert is not to attempt to refute every point the expert has made on direct examination. b. Translating Expert Testimony and Legalese into Plain English. Features of the Fort Worth Prairie extend into the West Cross Timbers along the eastern boundary, forming irregular ecotones of diverse tree and brush species common to both zones. Ask an expert who and what is considered authoritative in the field. Direct link to evanlin0312's post water can melt/dissolve/b, Posted 6 months ago. In Texas, this area includes the towns of Weatherford and Mineral Wells; Stephenville lies on the eastern fringe, while Brownwood is on the western edge. The Be Brief rule is hard to comply with if the same subject is covered several times. Feb 2014 Friends. Everyone knows this rule, but everyone also fails to follow it diligently. Direct link to lol.lamo.hi.bye's post Rocks are left out in the, Posted 21 days ago. The . If the expert refuses to answer a question, establish that on the record to set up a potential motion to strike the expert as a witness. 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." 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. Monthly Dividend Stock In Focus: Cross Timbers Royalty Trust Winter agricultural forage crops such as wheat and oats are commonly planted.
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