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Chapter 6 DIRECT EXAMINATION

Chapter 6 DIRECT EXAMINATION INTRODUCTIONThe DIRECT EXAMINATION of witnesses is the most important part of the may be more exciting and closing argument more eloquent,but it is the DIRECT EXAMINATION of your own witnesses that will determinewhether the jurors hear, understand, and remember the facts upon which yourcase is , DIRECT EXAMINATION often is done poorly. Witnesses are notpresented effectively, and attorneys fail to elicit coherent evidence from cannot just put a witness on the stand and ask, What happened? Yourdirect EXAMINATION must elicit what the witness knows in a manner that helpsthe jury understand, remember and believe it. Several obstacles stand in yourway that must be overcome:cYour witness is only human. A witness may know only a portionof the entire story, may have a poor memory, and even maycontradict other testify only in response to the questions you ask, whichplaces a burden on you to be comprehensive and rules of evidence limit the form of questions and the contentof testimony.

We might have as many as six construction projects going at once. This was what I had always wanted to do. I usually delegated most of the preconstruction planning, but I loved to direct the actual construction. That is when most of the crucial decisions had to be made. For instance, we might be working on the steel frame for

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