cross timbers deposition

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. We understand the importance of getting it done right. Much of the sub-region contains habitat that supports populations of white-tailed deer and other wildlife species. Elevations across the region range from 500 to 1,500 feet. Ford, J.S., 1963, Rip Ford's Texas. Private message. In some places, however, the oaks are of considerable size, and able to withstand the conflagrations. Direct link to 4035995's post Which one is more comman, Posted 5 months ago. Vast tall-grass native prairies once covered this region. Note the way to phrase the question-a true statement at the time it was written. Reveal number. Direct link to Mark's post Acid rain is about 100 ti, Posted 2 months ago. 200 - 300 year old Post Oaks can be found at: . Throughout its current range, the Cross Timbers forest ecosystem is vulnerable to land-use change. 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. There are extensive regions of grasslands and valleys with higher, narrow, often wooded mesa-like divides. 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. 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. 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. If the experts answers appear to defeat the credibility challenge posed by your questions, then you have lost and the expert has won. Your questioning style may be open-ended like a direct examination, narrow and controlling like a cross-examination, or a combination of the two. Plus, Cross Timbers pays a monthly dividend. Mechanical weathering is the creation of sediment through physical means. It served as a dividing line between the hunting grounds of the Plains Indians and East Texas Indians. 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. Either by nature or by circumstance, some witnesses will not remember important details, or claim not to remember important details. The towns of Sand Springs, Sapulpa, Ada, and Shawnee, Oklahoma fall within this large area; Bartlesville and Okmulgee lie on the eastern edge. 2287 0 obj <>stream Talk with the expert, if truthful and appropriate, about not framing answers in a way to appears partial to one side or the other. First, do not argue with the witness. The following, adapted from the Chicago Manual of Style, 15th edition, is the preferred citation for this entry. People spontaneously write e-mails without hesitation and, more importantly, without reflection or thinking. Email: CrossTimbers@uta.edu. Beyond discovering what happened, be clear on what two or three points you want to establish through a witnesss testimony. (Diggs et. 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. He lied when he wrote it? 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. This collection by wildflower.org lists native plants local to the Texas part of 29. https://www.epa.gov/eco-research/ecoregion-download-files-state-region-6#pane-41, https://www.epa.gov/eco-research/ecoregion-download-files-state-region-7#pane-14, Cross Timbers Historic Images ProjectTexas, Oklahoma Digital Maps: Digital Collections of Oklahoma and Indian Territory, List of census-designated places in Kansas, List of unincorporated communities in Kansas, National Register of Historic Places Sites, 120 Coastal Western Hemlock-Sitka Spruce Forests, 6 Southern and Central California Chaparral and Oak Woodlands, 29 Central Oklahoma/Texas Plains (Cross Timbers), 56 Southern Michigan/Northern Indiana Drift Plains, 60 Northern Appalachian Plateau and Uplands, 83 Eastern Great Lakes and Hudson Lowlands, 104 Interior Forested Lowlands and Uplands, https://en.wikipedia.org/w/index.php?title=Cross_Timbers&oldid=1139874580, Temperate grasslands, savannas, and shrublands in the United States, Articles with dead external links from November 2019, Articles with permanently dead external links, Articles with dead external links from July 2020, Articles with self-published sources from January 2018, Creative Commons Attribution-ShareAlike License 3.0. This is one of the only chances opposing counsel will have to directly poke holes in your case by attacking the credibility of your experts testimony. 0 [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. Review your understanding of weathering and erosion in this free article aligned to NGSS standards. This region was called the Upper Timbers by early travelers due to its higher elevation. In our business, there is no margin for error. For lawyers learning how to take depositions, there are a few guiding principles to keep in mind and a number of traps to avoid. Two fragments adjacent to Managing the Holidays After a Divorce With Children. It was also a formidable obstacle to travelers because of the density of growth. Development plans. Soils are slightly acidic, sandy or sandy loam, and produce woodlands dominated by post oak, blackjack oak, cedar elm, hickory, osage orange, eastern red cedar, mesquite, bumelia, hawthorn, greenbriar, and a variety of other brush and grass species. 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. I have a river in my backyard and when the rainwater evaporates i can see the dirt that got eaten at by the rain :^. 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. You should use these concessions to the extent possible to support your case. Direct link to Mahiro's post I have a river in my back, Posted 2 months ago. Historical records indicate much of this region existed as a grassland or open live oak savannah that supported herds of bison and other herbivores dependent on the tall grasses that dominated the region. 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. If the witness will be available at trial, your purpose more likely will be to elicit the witnesss story. This ecoregion exists as an enclave within the Western Cross Timbers, stretching from southern Jack County, Texas across northwestern Palo Pinto County into eastern Stephens County, as well as tiny parts of Young and Eastland counties. That means your side must come across as reasonable and polite. 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. 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. Deny that the document she wrote is a true statement? [3] Today, land use is a mixture of rangeland, pastures, and farmland. b. Translating Expert Testimony and Legalese into Plain English. 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. [8] Among the few major roads that cross the Limestone Cut Plains are US 281 north to south and US 84 east to west. Can acid rain dissolve human skin? It should be expected that opposing counsel will try to pigeonhole the witness testimony this way, so be sure to go over this with your expert. Preparation includes distilling the key points and determining how to convey them. Handbook of Texas Online, 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. Discuss tips with your expert, if appropriate, on how to rephrase some technical explanations and make them easier to understand. One of the best ways to get judges to interact with the experts testimony is to make his or her methodology both easy to understand and easy to use. The priority is and always should be not to compromise the credibility or image of your witness to the judge. In most jurisdictions, re-direct is limited to matters that were covered on cross. 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. 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. H@O@WF A 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). [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. Mehjabeen Rahman, Preparing an Expert Witness for Testimony A Checklist, The Expert Institute, (January 4, 2016), https://www.theexpertinstitute.com/preparing-expert-witness-trial-testimony//. To determine whether, if any of the facts as the expert understands them were changed, the expert would change his or her opinions. This transference is important because you need them not only to understand your expert but to actually stand in or become the expert in deliberations. (Was that what you meant by 'Which one is more comman'). Our skilled team makes sure we supply the correct court reporter in Cross Timbers for your case. Often what the expert says in response to a great question will provide the most powerful next question in your cross. Remind your expert of the role that he plays during direct examination and the litigation generally. 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/. The ending is what everyone always takes away. Website and Maintenance by Appeal Design, Court Reporting Cross Timbers, Missouri 65634. Fjarrgljfur looks like a really cool place to go camping. Although habitat for wildlife is present throughout the ecological region as a whole, populations vary considerably within sub-regions. Elevation increases gradually from southeast to northwest. deposition, such as using exhibits and cross-examination. Q: And that-to use your words-concerned you, isnt that true? 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? Anderson, Roger C., James S Fralish, Jerry M. Baskin (eds.). Direct link to tollitre000's post how does it start, Posted 4 days ago. This page was last edited on 17 February 2023, at 08:53. [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. 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. 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. If you are using documents, consider marking up the documents or drafting your questions on the documents, this can allow you to do follow-up questioning for each document as you go through the deposition. Numerous U.S. Discover 4 parks within 8.3 miles, including Lewisville Lake Environmental Learning Area, Coppell Nature Park, and Coppell Community . 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. 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. Texas State Historical Association (TSHA). In others, cross is open and can be directed to any subject that is relevant even if not addressed on direct. 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? Q: In fact, you anticipated that the contract production requirements were not met, isnt that true? The Ellsworth expedition, accompanied by Washington Irving, entered the cross timbers in 1832; later he wrote, " It was like struggling through forests of cast iron." Do not let the expert move from a topic if you think it has not been sufficiently addressed. Much of the land in this region is also used for livestock ranching for cattle, sheep, and goats. 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. There are other considerations that will guide your questioning style. 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. Eliciting Deposition Testimony: Real-World Application of Techniques. You also want to avoid being surprised. LOCATION. These experts may be susceptible to being put into a box for purposes of cross-examination. County . If you're seeing this message, it means we're having trouble loading external resources on our website. Before taking an expert's deposition, the parties should have completed fact discovery-interrogatories answered, documents obtained, lay witnesses deposed. The proposed buildings would total nearly 3.3 . The best way to prepare your expert for facing difficult questions on cross is to practice them with your experts, if appropriate. 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. Early travelers called this region the Monte Grande (Grand Forest) and later the Lower Timbers. Therefore, acid rain is far too weak to negatively affect your skin in any way. Having a plan of attack is key, especially with respect to the more highly technical aspects of your experts testimony. This region contains the cities of Fort Worth, Granbury and Denton, although Denton lies on the border with the Eastern Cross Timbers. Exposed sandstone rocks and boulders dominate landscape features in many areas. Direct link to I am Rhys's post Fjarrgljfur looks like, Posted 2 months ago. 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.". Comanches raided east of the Cross Timbers in the early years, and the Wichitas and others used the wood in the Cross Timbers. If you can do it at trial, you can do it at a deposition, and a lot more. 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. |-!U`&w. Kjj(-(pJ|wRrAG NA{A$3HL1Q8%_  H|OO@)HvBBMla=v=]@=4sIFv["iARDk5O $88][D4,)rs}%(DL`_"_"qw7)Ebh@iOUm Y2+kCunCQI olW Direct link to neela's post why does acid rain dissol, Posted a month ago. Surprisingly, however, these trees conceal their age very well. Although Cross Timbers also occur in Kansas and Texas, over half of the estimated 4.8 million hectares of that region are found in Oklahoma, making it the state's most abundant woody vegetation type. The natural vegetation is a woodland predominantly made up of dwarfed post oaks. The Trinity sands outcrop is an important intake area for meteoric water that forms important aquifers to the east where the formation continues in the subsurface. 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. Among the Pennsylvanian outcrops occur scattered exposures of hard limestones; without exception, such exposures are characterized by a typical savanna landscape, comprising scattered mesquite shrubs underlain by a floor of sod-forming short grasses. 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. 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. [2] The main highways that cross the region are I-35 and I-35W going north to south (although they tend to skirt the Cross Timbers' eastern fringe south of Fort Worth) and I-40 going east to west. Since the region has a subhumid climate, its natural vegetation would ordinarily be grass; its scrubby tree growth results from edaphic features. You must be clear about the purpose of your deposition. This way, it makes clear that your witness is not evading a difficult question, but is rather answering in the most accurate way possible. 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. Other factors such as fragmentation of once continuous habitat into smaller land holdings, competition for food and cover with livestock, conversion of woodland habitat to improved pastures or other agricultural enterprises, urban and rural developments, and lack of proper wildlife and habitat management also determine the density and diversity of wildlife. Best Winery In Grapevine. 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. Considerable urban growth and expansion throughout this region will continue to impact wildlife habitat resources in the future. The greater the familiarity, the greater the acceptance. Terms of Use | Privacy Policy Its location was well known and served as a landmark reference for travelers. Ask anticipated cross-examination questions. [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. 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. 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. B. 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. Weathering occurs when water breaks down rocks and soil to create sediment. 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. It will be easy to get angry and frustrated with an evasive, non-responsive witness. The region from one river to the other, is no less bountifully supplied with buffalo, bear, deer, antelope, wild boars, partridges, and turkeys. Failing to listen to the answers you are getting is the next most common pitfall. Remind your witness that I dont know is a perfectly acceptable answer, as long as that is the truth. 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 Main Belt and the Fringe together, though much interrupted, occupy the major portion of an area 150 miles long, varying in width from about 25 miles at the north to about 110 miles at the south.". The pH of acid-impacted rain is generally below 4.5 on the pH scale. In the western counties, where the average size of land tracts increases, cattle ranching is the predominant land use. 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. cross timbers deposition. endstream endobj startxref This allows you to bolster your experts credibility through the opposing expert. Post oak-blackjack oak woodlands characterize much of the West Cross Timbers. To log in and use all the features of Khan Academy, please enable JavaScript in your browser. ", In 1840, Col. In Oklahoma, scientists found a 500-plus-year-old red cedar and a 400-year-old post oak in Keystone Ancient . I. CPLR 3110 (1) A. Our court reporters, videographers, and team members have been educated on Huseby's in-person deposition guidelines. hVmoH+tw Judges hate repetition anyway because they are tired enough of the trial and dont want to watch the same hand played again. The second point in conveying a recognizable methodology to judges is creating familiar examples and analogies for the judge. endstream endobj 2265 0 obj <>stream It has budgeted $70-90 million for E&D spending this year. Remind your expert not to get defensive if they feel attacked by a line of questioning. The Eastern and Western Cross Timbers are formed by a narrow band of woodland extending along Red River. 4 Y`c<6 #(@N1r 7maaX#vA Sure Dividend has compiled a database of 84 . 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. 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? 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. As you are walking the expert through the steps of their methodology, it is also important to ask them about what they were thinking as they looked at the data or results that they were seeing. [4] The Cross Timbers are contained within the WWF central forest-grasslands transition ecoregion. We understand the need to use the highest quality reporter for you. You must establish control early by making the expert answer your question. Watersheds of the Red, Colorado, Trinity and Brazos Rivers cross the region from northwest to southeast. 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. First, consider whether the case is likely to proceed to trial. 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. Cross Timbers Royalty Trust (CRT) is a micro-cap, and a tiny one at thatit has a market capitalization of just $145 million. 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.

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