cross timbers deposition

with let's say a sm, Posted 3 months ago. In 1772, De Mezieres (Dyksterhuis 1948) stated that from the Brazos River north "one sees on the right a forest (East Cross Timbers) that the native appropriately call the Grand ForestSince it contains some large hills, and because of the great quantity of oaks, walnuts, and other large trees, it is a place difficult to crossOn the farther edge of this range, or forest, one crosses plains having plentiful pasturage;" and in 1778 "I crossed the Colorado and Brazos, where there arean incredible number of Castilian cattle, and herds of mustangs that never leave the banks of these streams. About 17 million acres are represented by this region of alternating bands of wooded habitat scattered throughout a mostly prairie region. Language links are at the top of the page across from the title. Yes. What is the witness to do? Portions of the Trinity sands area are now important in peanut culture as well as for the growing of small fruits. If not, then you can use every piece of ammunition you have and can completely attack the witness and cross-examine on every weak point because that will give you value for settlement. 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. "[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]. 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. You must reduce the issue you are addressing to a knowledge level that will convince the judge that what the expert has sold them on direct is inconsistent with the common sense that you will be emphasizing they need to use to decide the case in closing argument. Cross Timbers' acquisition strategy has given it a sizeable portfolio of drilling prospects. Exposed flat topped buttes and escarpments capped by Edwards limestone which have been eroded over most of the region. This field is for validation purposes and should be left unchanged. Ensure that you have covered all bases for each opinion by asking catchall questions such as Are there any other bases for this opinion that you have not already mentioned? Make sure you keep asking that question until the answer is a definitive no. Then, move on. In our business, there is no margin for error. Our skilled team makes sure we supply the correct court reporter in Cross Timbers for your case. In this study, we examined the surrounding land use matrix on the vegetation structure, composition and regeneration of six Cross Timbers forest fragments in Denton County, Texas (north of the Dallas -Fort Worth metroplex). Be persistent. Posted 6 months ago. 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. Most of this region is underlain by various limestone formations. Our reporters that cover Cross Timbers are highly skilled in their craft, and they are ready to meet your specific case needs. 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. The East Cross Timbers - In Northcentral Texas, the East Cross Timbers vegetative sub-region is a narrow strip of timbered country extending from eastern Cooke County on the Red River south to western Hill County and includes portions of Denton, Tarrant, Johnson, and Hill counties. Cross Timbers oaks are used for firewood, railroad ties, and poles, but the most important function of the timber belt is preserving water. 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. 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. This region contains the cities of Fort Worth, Granbury and Denton, although Denton lies on the border with the Eastern Cross Timbers. Direct link to jacobson.mia's post Can erosion happen fast t, Posted 5 months ago. Direct link to Mahiro's post I have a river in my back, Posted 2 months ago. Soils at the surface, consequently, support the growth of plants adapted to higher alkalinity, such as live oak and juniper. 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. 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. Ford, J.S., 1963, Rip Ford's Texas. Soils of the East and West Cross Timbers were developed on sandy Cretaceous Woodbine and Trinity strata. 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. Cross Timbers, Current Projects. It was also a formidable obstacle to travelers because of the density of growth. {}~ysZ=*dv-v^AhYAuuBWy=(G0Y7eJd#YR2L$U4EB/t0 To determine whether, if any of the facts as the expert understands them were changed, the expert would change his or her opinions. If the attorney insists on cutting off your witness, instruct your witness to answer the next question by stating the previous question was not completely or accurately answered. Nice! Review your understanding of weathering and erosion in this free article aligned to NGSS standards. If the expert continues to offer an evasive non-answer, you must redirect the expert to your question and make him or her answer it. Vast tall-grass native prairies once covered this region. In most jurisdictions, re-direct is limited to matters that were covered on cross. HVpTWg6o@ <6dw#H1Vwl&$ )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]! If there is any significant doubt of who will win the point, leave the question on the cutting room floor. Direct link to neela's post why does acid rain dissol, Posted a month ago. LOCATION. What evidence of weathering erosion and deposition exists in . Dan Goldman and Mor Wetzler, How to Take a Deposition, ABA Young Advocates Section of Litigation, (April 4, 2011), http://apps.americanbar.org/litigation/committees/youngadvocate/articles/spring2011-take-deposition.html/. PDF Structure, Composition, and Regeneration of Cross Timbers Forest 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. You also want to avoid being surprised. [2] I-35 crosses this region north to south. V. CPLR 3113 [c] examination and cross-examination of deponents shall proceed as permitted in the trial of the actions in open court A. PDF 6. FUNDAMENTALS OF DEPOSITIONS - New York State Bar Association The Arbuckle Mountains are located in a small area nestled in between regions 29g and h; it is made of folded, rather than dissected, limestone, sandstone, and dolomite, and features the greatest topographical relief of the entire Cross Timbers, though not the highest elevations. [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. H@O@WF A Management of habitat for white-tailed deer and other wildlife species in the Lampasas Cut Plain sub-region can be financially rewarding to landowners and land managers. [5] The prairie portions are chiefly tallgrass on finer, dry soils. Depositions & Cross Examinations: Best Practices & Strategies Most of the timber appears to be kept small by the continual inroads of the "burning prairies;" for, being killed almost annually, it is constantly replaced by scions of undergrowth; so that it becomes more and more dense every reproduction. 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. 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. It holds 90% net profits interests in certain producing and nonproducing royalty and overriding royalty interest properties in Texas, Oklahoma, and New Mexico; and 75% net profits working interest in four properties in Texas and three properties in Oklahoma. Cross Timbers | The Encyclopedia of Oklahoma History and Culture Direct link to 4035995's post Which one is more comman, Posted 5 months ago. 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. If you are careful about using leading questions, you will substantially limit the likelihood of the expert being able to successfully say that he needs to explain. Test each question in your outline by asking, can you successfully cut the expert off to a yes or no? The presettlement Cross Timbers are believed to have covered approximately 28,000 square miles (7,250,000 hectares), extending from central Texas across . Winter agricultural forage crops such as wheat and oats are commonly planted. Cross Timbers Ecosystem | Cross Timbers Urban Forestry Council Failing to listen to the answers you are getting is the next most common pitfall. 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/. Q: And that-to use your words-concerned you, isnt that true? cross timber: [noun] a strip of woodland chiefly of oaks stretching across grassland especially in Texas. See for yourself why so many call us their reporting company. The timber prevents rain water from immediately running off the surface and causes much of it to soak into sand that supplies artesian water for hundreds of wells to the east and south of the Cross Timbers. Direct link to Levi's post Can acid rain dissolve hu, Posted 6 months ago. Farm and ranch size is relatively large, making accomplishment of land management strategies for wildlife and habitat both productive and feasible. A: Yes. Since the region has a subhumid climate, its natural vegetation would ordinarily be grass; its scrubby tree growth results from edaphic features. Many trial judges create their own rules of courtroom behavior. Covering a fairly small area in south-central Oklahoma and underlain by a unique mosaic of several different minerals, this region includes the town of Ardmore. Remind your expert not to get defensive if they feel attacked by a line of questioning. While planning for your future may seem like a daunting task, When one person in a couple is in the military, their divorce may be substantially different from a traditional civil divorce. Most grasslands have been degraded and remain only as remnants where shallow soils prevented cultivation. The company plans to . If you can do it at trial, you can do it at a deposition, and a lot more. [5] These old-growth forests contain millions of post oak from 200 to 400 years old and red cedar over 500 years old. [19]:116, Coordinates: .mw-parser-output .geo-default,.mw-parser-output .geo-dms,.mw-parser-output .geo-dec{display:inline}.mw-parser-output .geo-nondefault,.mw-parser-output .geo-multi-punct{display:none}.mw-parser-output .longitude,.mw-parser-output .latitude{white-space:nowrap}3400N 9715W / 34.000N 97.250W / 34.000; -97.250. The term "Cross Timbers" refers to an ecological region of woodland and forest vegetation in central and eastern Oklahoma. Richard Gabriel, Redefining Credibility: Turning Expert Witnesses into Teachers, The Jury Expert, (May 1, 2009), http://www.thejuryexpert.com/2009/05/redefining-credibility-turning-expert-witnesses-into-teachers/. . 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. Extensive areas are still used for livestock grazing, but climax plant communities have been altered. Fax: 817-272-5977. "Acid rain is caused by the release of sulfur dioxide and nitrogen oxides into the atmosphere, where they react with water, oxygen, and other chemicals to become sulfuric and nitric acid respectively. In the western counties, where the average size of land tracts increases, cattle ranching is the predominant land use. Discover the #1 platform to conduct a deposition from the comfort of your home or office, providing you a first-class virtual deposition experience and live support from Huseby techs. hb```e``c`230 P9CLlll?9qZHx*"9p1qrxqmG\B/_8:x89vsp\==c/vq\\wUz2Ev={mnmwoIxv;D@YY .l @dp&0f X;"@ Numerous roads cross this region, including US 70 in Oklahoma and I-20, I-30, US 67, US 81, US 82, US 180, US 183, US 281, US 287, and US 380 in Texas. If you find that the cross is going to take longer than that, you should seriously consider cutting it back. Note the way to phrase the question-a true statement at the time it was written. A: Yes. The . Best Winery In Grapevine. Exactly What Are the Cross Timbers? - LakeTexoma.com The other party only gets to cross examine the witness. PDF Texas Conservation Action Plan Crow Holdings' site plan proposal for the Cross Timbers Business Park, a 10-building warehouse park in the northwest corner of FM 1171 and Hwy 377. Ecologically, the EPA includes the Cross Timbers as part of the vast Great Plains, which comprise Level I Ecoregion 9.0, stretching from central Alberta in Canada to northern Mexico. |-!U`&w. Kjj(-(pJ|wRrAG NA{A$3HL1Q8%_ 4 Y`c<6 #(@N1r 7maaX#vA Having a plan of attack is key, especially with respect to the more highly technical aspects of your experts testimony. There are two main types of weathering: mechanical and chemical. You may need to object and then move to strike portions of the experts answer. Mechanical weathering is the creation of sediment through physical means. The second point in conveying a recognizable methodology to judges is creating familiar examples and analogies for the judge. Indians used the Cross Timbers as a north-south avenue that afforded secrecy from enemies. 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. For example, if you know that a witness will not be available at trial and the deposition is being videotaped, you may want to treat the deposition as a cross-examination. It will be easy to get angry and frustrated with an evasive, non-responsive witness. Cross Timbers. 0 1999). In Cross Timbers, we will need to find a location to host your deposition. Leasing land for deer hunting is an important economic enterprise of the sub-region. 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. [2] Overall, the Cross Timbers are not as arable as the surrounding ecoregions. Often what the expert says in response to a great question will provide the most powerful next question in your cross. 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. [2] Although local relief is relatively low, it is generally greater than that in the surrounding ecoregions, although this is not the case with the Flint Hills in Kansas.[4]. Remind your witness to leave the door open for clarification on re-direct. Direct link to lol.lamo.hi.bye's post Rocks are left out in the, Posted 21 days ago. For example: Q: And when you wrote that I cannot justify paying so much for senior staff when we are missing our budget, you believed that to be a true statement, didnt you? https://www.tshaonline.org, https://www.tshaonline.org/handbook/entries/cross-timbers. He lied when he wrote it? Be persistent, but polite. The proposed buildings would total nearly 3.3 . Early travelers called this region the Monte Grande (Grand . 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. *0K7N(s[_/YS!Y ~ZlAiwcxPfyU+u 9pp`9mIyve~6?scv;CP'uS5R,w+cZ}\&Jt"Z5oH]o>%sV\!bEDd.c7|J}4$/ka' W\0Occ= Reveal number. However, in some instances, there can be a concern that opposing counsel may inquire as to what you talked to the expert about prior to trial. Good experts have probably spent several times as many hours on cross in a courtroom as you have. When you plot out cross examination, go carefully through the documents, especially the e-mails. They may be considered as the "fringe" of the great prairies, being a continuous brushy strip, composed of various kinds of undergrowth; such as black-jack, post-oaks, and in some places hickory, elm, etc., intermixed with a very diminutive dwarf oak, called by the hunters, "shin-oak." Pinewood Hills Independent Senior Living Apartments 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 . Direct link to braalt02's post Yes. And not using every single question seems to leave some of your great ideas at home. Its location was well known and served as a landmark reference for travelers. What Are the Benefits of Having an Estate Plan? What is the witness to say? What evidence of weathering erosion and deposition exists in - Answers Ecoregion 5 - The Cross Timbers and Prairies - Texas If the witness will be available at trial, your purpose more likely will be to elicit the witnesss story. 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. Often, an expert such as a treating doctor who is not an outright advocate for the other side will concede points when appropriate. If the experts answers appear to defeat the credibility challenge posed by your questions, then you have lost and the expert has won. u+W Go|iATB5B!te=MPY ~2@Y;(JB~7@$ V! @"\X^qOy$)EG:skr cM+k]a|jA`W>rkI *i68i=.UhsMNdU2~&o r.J"~e(^MTmvAU/ 5h5 iSUg3w|I-j5X W]BZg4Hw vX$ Early travelers called this region the Monte Grande (Grand Forest) and later the Lower Timbers. Usually, it will take several narrative answers before you can expect the judge to step in and instruct the expert to respond, but asking for the judges help (if you get it) sends a powerful message that the expert is trying to be evasive. The expert may provide an even more perfect setup for your next question than your question did. If you change your mind, you can easily unsubscribe. Cross Timbers Royalty Trust operates as an express trust in the United States. Your questioning style may be open-ended like a direct examination, narrow and controlling like a cross-examination, or a combination of the two. Some of these can be onerous, imposing time limits on examination and otherwise restricting the courtroom latitude of trial attorneys who have become accustomed to a more generous approach. 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. Cross Timbers Royalty Trust (CRT) is a micro-cap, and a tiny one at thatit has a market capitalization of just $145 million. In Oklahoma, scientists found a 500-plus-year-old red cedar and a 400-year-old post oak in Keystone Ancient . I am curious. Retained experts are notoriously difficult to control, particularly for a new lawyer. 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. If you doubt that, go back and look over the last cross examinations you have handled. The most important tip to remind your witness is to stop, breathe and think about the question being asked before providing an answer. We need your support because we are a non-profit organization that relies upon contributions from our community in order to record and preserve the history of our state. Every person works hard to collect different property, investments, and assets throughout their life. [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. Terrain of the mostly treeless vegetative region, located north of the Brazos River, is characterized by gently sloping flat surface features with thin soil over hard layers of resistant limestone. When an opposing expert is willing to render opinions favorable to your case, do not be afraid to make use of that testimony. The areas of ancient Cross Timbers still remaining are some of the last virgin North American hardwood forests. Two fragments adjacent to For lawyers learning how to take depositions, there are a few guiding principles to keep in mind and a number of traps to avoid. In addition to not letting an expert push you around, you must be persistent in following through with your line of questions. Home; Projects. Hundreds of e-mails. Posted on Nov 14, 2016. Home; Projects. with let's say a small rock, sure it can take a while to break it down, but eventually the small rock will break but it won't take as long as it would for a big rock. Even if you do nothing else while deposing an expert witness, at least make sure you confirm that the expert has told you all his or her opinions about the case. A fairly narrow strip dividing the Eastern and Western Cross Timbers, the Grand Prairie differs in physiography, topography, and land use from both of these, as it is much more nearly level and better suited to agriculture. [8] Among the few major roads that cross the Limestone Cut Plains are US 281 north to south and US 84 east to west. That means your side must come across as reasonable and polite. (Was that what you meant by 'Which one is more comman'). Cotton and corn are also grown. The attorneys objective on cross is to weaken the experts testimony and thus will undoubtedly frame yes or no questions in such a way to achieve that purpose. Thus, its always advisable to simply tell experts to tell the truth. The priority is and always should be not to compromise the credibility or image of your witness to the judge. Call Discovery at (855) 847-0999. The ending is what everyone always takes away. Numerous U.S. No matter how many times an expert has testified at trial, being grilled during cross-examination is always incredibly stressful. This allows you to bolster your experts credibility through the opposing expert. The advent and indeed overuse of e-mails has made cross-examination through the use of documents even simpler, and the use of depositions almost superfluous. Argyle ISD Board considering resolution of - Cross Timbers Gazette 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.