Cross Timbers oaks are used for firewood, railroad ties, and poles, but the most important function of the timber belt is preserving water. The trees served as a testament to the harshness of the environment. Another strategy to handle this type of question is to say in some circumstances if that is the case. Remember the cardinal rule of cross examining and ask only short and simple factual statements. What to do when a Witness is Being Evasive of Defiant. There are two main types of weathering: mechanical and chemical. If the last area of questioning finishes off the experts credibility, you have one. Court Reporting Missouri/court Reporters Cross Timbers/ After the introduction of domestic livestock, farming operations, and control of wildfires, the landscape of much of the Lampasas Cut Plain changed. Signup today for our free newsletter, Especially Texan. Leasing land for deer hunting is an important economic enterprise of the sub-region. Wildlife management in the East Cross Timbers will prove to be challenging to landowners and will require innovative approaches to management of the habitat resources found there. The proposed buildings would total nearly 3.3 . 2287 0 obj <>stream ", In 1840, Col. you may want to treat the deposition as a cross-examination . 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. 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 . (see LOWER PLAINS.). As you approach the deposition date, if the event cannot go forward, no problem, up to 24 hours (business day) prior to the event you can reschedule or cancel with no penalty. All rights reserved. Soils of the East and West Cross Timbers were developed on sandy Cretaceous Woodbine and Trinity strata. and cookie statement. 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. Ford, J.S., 1963, Rip Ford's Texas. [2][8], A much wider band than the Eastern Cross Timbers, the Western Cross Timbers band extends from far southern Oklahoma, including parts of Love and Carter counties, into central Texas, where it covers large parts of Montague, Young, Jack, Wise, Stephens, Palo Pinto, Parker, Eastland, Erath, Brown, San Saba, and Mills counties, as well as smaller parts of Clay, Cooke, Callahan, Hood, Coleman, and McCulloch counties. 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. If there is a good likelihood the case may be tried, you may want to hold some of your strongest attacks. Often what the expert says in response to a great question will provide the most powerful next question in your cross. endstream endobj 2262 0 obj <>/OCGs[2274 0 R]>>/Pages 2246 0 R/StructTreeRoot 450 0 R/Type/Catalog>> endobj 2263 0 obj <>/Font<>/ProcSet[/PDF/Text]/XObject<>>>/Rotate 0/Type/Page>> endobj 2264 0 obj <>stream [2] Overall, the Cross Timbers are not as arable as the surrounding ecoregions. Note the way to phrase the question-a true statement at the time it was written. The expert may provide an even more perfect setup for your next question than your question did. It will be easy to get angry and frustrated with an evasive, non-responsive witness. To log in and use all the features of Khan Academy, please enable JavaScript in your browser. Much of the land in this region is also used for livestock ranching for cattle, sheep, and goats. If you did not ask that catchall question at the deposition and cover all of the opinions the expert has, and the expert then renders at trial opinions you were not aware of, your case could be endangered. Fax: 817-272-5977. Is Alternative Dispute Resolution Right for You? The minute you are arguing with the witness, you are not going to win. Some exposed surface formations in the western part of the West Cross Timbers date from the 300-million-year-old Pennsylvanian Period. It will almost always be where you allowed the expert to take control of the traffic and begin to explain what she had already carefully explained on direct examination. Pinewood Hills Independent Senior Living Apartments 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? ", without weathering, erosion isn't possible, so I'd say weathering. Extensive areas are still used for livestock grazing, but climax plant communities have been altered. Plus, Cross Timbers pays a monthly dividend. 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. If not, consider whether that question should be dropped or recast. If the witness cannot remember key details, you will sometimes have deposition testimony or other extrinsic evidence to rely on, which will be helpful in refreshing the witnesss memory. [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. PDF Structure, Composition, and Regeneration of Cross Timbers Forest Post oak-blackjack oak woodlands characterize much of the West Cross Timbers. 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. 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? In the Fort Worth Prairie and Lampasas Cut Plain, shallow soils were formed over Cretaceous limestone parent materials. Home; Projects. How acidic is Acid Rain and how does it happen. 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. with let's say a sm, Posted 3 months ago. Q: In fact, you anticipated that the contract production requirements were not met, isnt that true? Email subscriber privacy policy 2022 by Stange Law Firm, PC. endstream endobj 2265 0 obj <>stream This was an important influence on early settlement as underground water was available from shallow wells dug into the Trinity sands. What evidence of weathering erosion and deposition exists in . 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. The average width of the Eastern Cross Timbers does not exceed fifteen miles, and its features disappear near the Brazos at Waco. 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. 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. Many trial judges create their own rules of courtroom behavior. The Cross Timbers bands made travel difficult for settlers, yet the ecosystem provided for their basic needs. Ecoregion 5 - The Cross Timbers and Prairies. PDF Weathering, Erosion, and Deposition: Trans Pecos/Chihuahuan Desert Weathering occurs when water breaks down rocks and soil to create sediment. Is chemical or mechanical weathering more common? First, do not argue with the witness. Some organizations and maps refer to the Cross Timbers ecoregion as the Central Oklahoma/Texas Plains. They are always waiting for you to give them an opportunity to reiterate their favorite themes. 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. 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. When you choose us, you dont have to sacrifice quality or service. Cotton and corn are also grown. Yes. 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. Most of this region is underlain by various limestone formations. There are extensive regions of grasslands and valleys with higher, narrow, often wooded mesa-like divides. Current Projects. You may be able to find information in the treatise or from one of the authors that contradicts the experts opinions. Find out which treatises or authors the expert considers to be authoritative in the field. Direct link to pbro7467's post How acidic is Acid Rain a, Posted 3 months ago. This field is for validation purposes and should be left unchanged. The . The historical structure of the Cross- Timbers forests in this region has been altered, mainly due to fire exclusion, such that the current . It passes through northwestern Grayson County, eastern Cooke, Denton and Tarrant counties, central Johnson County, western Hill County, and northern McClennan County. 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. Other associated woody species include shin oak, Spanish oak, live oak, Texas ash, mesquite, osage orange, Ashe juniper, eastern red cedar, cedar elm, skunkbush sumac, elbowbush, lotebush, tasajillo, rough-leafed dogwood, flame-leaf sumac, hawthorn, and hackberry. 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. S. Fort Worth, Texas 76118. Posted 6 months ago. Direct link to I am Rhys's post Fjarrgljfur looks like, Posted 2 months ago. The region is well adapted for truck farming. 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. Failing to listen to the answers you are getting is the next most common pitfall. Owing to the fact that the parent materials are prevailingly noncalcareous, both the soils and the natural vegetation of the Western Cross Timbers areas differ sharply from soils of adjacent areas underlain by either "hard" or "soft" formations that are also highly calcareous. . When you plot out cross examination, go carefully through the documents, especially the e-mails. The choice of a lawyer is an important decision & should not be based solely upon advertisements. 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). Some rules may affect what you are allowed to do on cross examination. Cross Timbers Winery (Grapevine) - All You Need to Know - Tripadvisor If there is any significant doubt of who will win the point, leave the question on the cutting room floor. Cross Timbers' acquisition strategy has given it a sizeable portfolio of drilling prospects. 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. Thus, its always advisable to simply tell experts to tell the truth. III. cross timbers deposition This broad vegetative region also extends northward into Oklahoma and southern Kansas. Plaintiff Ken Burger ("Burger") is an Ohio citizen who resides in Cincinnati, Ohio. 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. 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. Instead, it might be better to use a pure discovery deposition to pin down what a witnesss story will be without revealing your best documents. The areas of ancient Cross Timbers still remaining are some of the last virgin North American hardwood forests. Elicit all the experts opinions and bases of opinions. 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. 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. You may need to object and then move to strike portions of the experts answer. To determine whether, if any of the facts as the expert understands them were changed, the expert would change his or her opinions. 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." Ecoregion 5 - The Cross Timbers and Prairies - Texas Soils at the surface, consequently, support the growth of plants adapted to higher alkalinity, such as live oak and juniper. That means your side must come across as reasonable and polite. Fjarrgljfur looks like a really cool place to go camping. In pioneer times the band of timber was a famous landmark. Posted on Nov 14, 2016. II. If you change your mind, you can easily unsubscribe. 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. You must elicit that information so, among other things, your own expert will be able to identify points of criticism or disagreement. Topographic types in the region vary with the major geologic formations that outcrop in the area. It is very important for you to generally remain the noble person who is confronting the expert. We have the experience to deliver. Judges hate repetition anyway because they are tired enough of the trial and dont want to watch the same hand played again. endstream endobj 2266 0 obj <>stream What is the witness to do? The most important tip to remind your witness is to stop, breathe and think about the question being asked before providing an answer. *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= The following, adapted from the Chicago Manual of Style, 15th edition, is the preferred citation for this entry. Login (855) 847-0999 calendar@huseby.com People spontaneously write e-mails without hesitation and, more importantly, without reflection or thinking. 0 If the case goes to trial, usually only a very small part of the deposition is ever used. Today, few large tracts of undisturbed woodlands remain in the East Cross Timbers which is perhaps the most fragmented vegetative region in Texas. 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. This way, you are not misleading the court by answering yes or no if the answer truly is sometimes. This paints a better picture for your expert as a credible witness and also weakens opposing counsels line of questioning. The region has been important chiefly for its mineral resources. 7300 Jack Newell Blvd. The soil is thin, sandy, and poorly watered. The altitude of the belt is slightly higher than that of the surrounding prairies. 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. Talk with the expert, if truthful and appropriate, about not framing answers in a way to appears partial to one side or the other. ", Other historic accounts by early travelers in north and central Texas record a much different Texas landscape in many areas that is difficult for us to imagine today. See additional disclaimers, MISSOURI, ILLINOIS, KANSAS, OKLAHOMA, & NEBRASKA FAMILY LAW ATTORNEYS, Charitable Giving and Community Involvement. 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. Put the expert into a box. 4 Y`c<6 #(@N1r 7maaX#vA 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. This zone also includes portion of Archer, Clay, Wise, Young, Throckmorton, Shackelford, Jack, Tarrant, Parker, Palo Pinto, Stephens, Callahan, Eastland, Erath, Hood, Somervell, Johnson, Hamilton, Comanche, Mills and Brown counties. Login (855) 847-0999 calendar@huseby.com And not using every single question seems to leave some of your great ideas at home. 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. When preparing for cross, every question should be analyzed to see which of those three things are challenged. All rights reserved. [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. Depositions & Cross Examinations: Best Practices & Strategies Weathering, Erosion and Deposition: Cross Timbers and Prairies The landscape is categorized by irregular plains with acidic soils along the parallel ridges and valleys, sandy and sandy loam soils on the uplands, and clay and clay loams occupy the low-lying areas. The deposition of an expert witness is the culmination of the opposing party's defense or prosecution theory of the case. Many woodland areas in this region have been cleared for tame-grass pastures, croplands, horse and cattle ranches, and urban and rural developments, including portions of the cities of Denton, Dallas, Fort Worth, and other expanding inter-city and rural communities. Second, within that framework, determine what you hope to accomplish through the deposition. Cross Examination Rules, Strategies and Traps to Avoid. The best way to prepare your expert for facing difficult questions on cross is to practice them with your experts, if appropriate. 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. Take the lead on how to engage the judge. 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. Sometimes experts are advocates for the parties that have retained them. 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. Elevation increases gradually from southeast to northwest. Cross timber Definition & Meaning - Merriam-Webster Exposed sandstone rocks and boulders dominate landscape features in many areas. For example, you may want to wait to use some documents at trial to surprise a witness and not allow him or her time to think of an explanation for a document. any personal information to the agency. The rich loam soils now support agricultural croplands that produce cotton, corn, oats, wheat, sorghum, milo, and other crops. In many instances, opposing counsel may cut off your expert in the middle of an answer, especially if the answer isnt favorable to their story of the case. Your conduct should always remain respectful. There is nothing gained by appearing to become angry and frustrated by the experts unwillingness to concede points that she should obviously concede. 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. They merely e-mail each other. 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. We are drowning in a flood of e-mails, and they are all part of e-discovery. 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. It served as a dividing line between the hunting grounds of the Plains Indians and East Texas Indians. Cross Timbers Royalty Trust (CRT) - Stock Analysis If you find yourself getting upset or emotional, it probably means that you know you are losing the debate, and it may mean it is time to think about stopping. Do not take an opposing experts deposition until you have a firm outline and strategy for accomplishing your goals with the expert witness; otherwise, you are not likely to have any success either undermining or limiting the impact of the expert. The Be Brief rule is hard to comply with if the same subject is covered several times. 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. Your questioning style may be open-ended like a direct examination, narrow and controlling like a cross-examination, or a combination of the two. Elevations across the region range from 500 to 1,500 feet. . [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. hb```e``c`230 P9CLlll?9qZHx*"9p1qrxqmG\B/_8:x89vsp\==c/vq\\wUz2Ev={mnmwoIxv;D@YY .l @dp&0f X;"@ Every dollar helps. The term Cross Timbers, also known as Ecoregion 29, Central Oklahoma/Texas Plains, is used to describe a strip of land in the United States that runs from southeastern Kansas across Central Oklahoma to Central Texas. [5] The prairie portions are chiefly tallgrass on finer, dry soils. 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. When examining this type of witness, it is particularly important to ask short, concise questions that are statements of fact. %PDF-1.7 % You also want to avoid being surprised. You get the resources of a large divorce and family law firm AND the attentive service of a local attorney.

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