[blindLaw] Preparing for and taking notes on cross examinations

carlos Montas montascarlos267 at gmail.com
Thu Feb 10 18:10:19 UTC 2022


Good afternoon Lauren my name is Carlos Montas. We have spoken before on clubhouse in the Seeing Eye room. I was wondering if we could schedule a time to discuss investigative techniques? I just started a new job with the Equal Employment Opportunity Commission as an investigator. I am not a lawyer, but I figured a leagal perspective would be helpful.  I can reached  at 305-527-0192. 
Soincerely, Carlos Montas  
Sent from my iPhone

> On Feb 10, 2022, at 9:45 AM, Lauren Bishop via BlindLaw <blindlaw at nfbnet.org> wrote:
> 
> Hi all,
> I thank you for all of your responses. I definitely plan to have an outline of course, I just wanted to know how you guys added to it. This all seems very helpful, and I plan to play around with one note and see if that is a good solution also. 
> Thanks,
> Lauren
> 
> Sent from my iPhone
> 
>> On Feb 10, 2022, at 9:53 AM, Teresita Rios via BlindLaw <blindlaw at nfbnet.org> wrote:
>> 
>> I love Trial Advocacy
>> 
>> 
>> For cross, Robb, is correct.
>> I wrote my cross ahead of time, because We have to be ready to impeach the
>> Witness (just in case)  so having page numbers, paragraph numbers and line
>> numbers  from the deposition and exhibits in all of my lines is super
>> important.
>> I have several docs opened.
>> One was a impeachment script, another was my cross, and another was my
>> exhibits and depositions. (all with headings and sub headings)
>> 
>> I just take notes of the opposing council's direct, if they addressed
>> interesting arguments I have not thought of or herd before.
>> My notes go on the top of my prepared cross,
>> I also used lots of headings too.
>> In cross I am just, trying to admit the key facts to build my Closing
>> arguments. So if in the process of doing that I can bring exhibits and
>> deposition facts that create doubts of the statements or motives or
>> character of the witness, that is only extra points.
>> 
>> So for redirect notes. I just added a deviding line with lots of
>> - (dashes)
>> Before the dash I have my fleshed out direct outline,
>> With headings, and a side (finder panel displaying the headlines) so i
>> always have access to an outline of my notes and I can jomp to any argument
>> I have
>> 
>> under the dashes I have my re direct., notes, try to think of arguments
>> ahead of time. But sometimes there are some new ones and the best part is
>> to not tuch those. Unless  you have a good defence or fact addressing that
>> point.
>> 
>> Work on an argument for closing though. But  focus only on your strongest
>> facts/exhibits that rebut what was directly addressed on Cross.
>> 
>> I only use my computer, and a screen reader with earbuds.
>> --
>> on the other hand, if I am taking notes on the cross of my partner?
>> then I write it on Word and (discreetly push my computer away from me to
>> let them read my notes from far away. use a 28 bold font. Haha.
>> You can also talk to them in whispers.
>> 
>> Attached you will find my  impeachment script.
>> Use transition lines to guide the jury and some closed question starters.
>> 
>> Best of luck, and have fun!
>> Teresita Rios
>> 
>> 
>>> On Thu, Feb 10, 2022 at 8:14 AM Robert Munro via BlindLaw <
>>> blindlaw at nfbnet.org> wrote:
>>> 
>>> The main thing I have found with cross examination is to prepare it in
>>> advance. Write down topics you want to address as headings and or
>>> subheadings. Then move through them while you’re doing your cross
>>> examination by jumping from heading to heading in case you want to take up
>>> topics in a different order than you wrote them down originally.
>>> 
>>> As for taking notes, you might want to do that in a separate document in
>>> case you get aPerry Mason-style gift gift during the person’s testimony.
>>> You can’t count on that though. That’s why preparation is key.
>>> 
>>> Onward!
>>> 
>>> Rob
>>> 
>>>> On Feb 9, 2022, at 22:51, Lauren Bishop via BlindLaw <
>>> blindlaw at nfbnet.org> wrote:
>>>> 
>>>> I forgot to mention that I have a braille display, and I have it always
>>> connected to my computer through Bluetooth so I can move around the quart
>>> room and still have my braille display.
>>>> 
>>>> Sent from my iPhone
>>>> 
>>>>> On Feb 9, 2022, at 10:48 PM, Lauren Bishop via BlindLaw <
>>> blindlaw at nfbnet.org> wrote:
>>>>> 
>>>>> Hi all,
>>>>> I am currently taking a trial advocacy course, and I have to do cross
>>> examinations next week. The professor mentioned using some sort of trial
>>> paper for students to take notes while the other side is examining the
>>> witness. As blind people, what are some methods that you have used to do
>>> this? I am a screen reader user, and I can’t read large print.
>>>>> Thanks,
>>>>> Lauren
>>>>> 
>>>>> Sent from my iPhone
>>>> 
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