Ask one fact per question.
Avoid long and compounded cross examination questions.
Be simple.
Be direct to the point.
Limit your cross examination questions to "yes" or "no" format.
Tie the hands of the hostile witness to "yes or no questions".
Ask only questions where you know the answers.
Do not let the hostile witness explain his answer.
(Let his own lawyer do that on his re-direct examination).
Unless absolutely necessary, do not ask questions that start with "who", "what", "when", "where", "why" and "how".
These question's are good only for direct and re-direct examination questions (case build-up questions).
Know when not to cross examine a truthful witness.
Know when to shut up and sit down.
The goals of cross examination are to seek the Truth and to test the credibility of the witness and his testimony.
Cross examination is not intended to massage your ego as a trial lawyer or as an investigating legislator.
The secret of successful cross examination is PREPARATION.
Master your case.
Know the Applicable Law and Jurisprudence.
Organize your evidence.
Know the eccentricities and character traits of the Judge and the adverse counsel.
Destroy the credibility of the hostile witness without necessarily quarreling with him in open court.
Destroy the hostile witness by the quality of your cross examination questions, not by the volume of your voice or your bloated ego.
Be well-rested and well-fed before the trial/hearing.
Let your mind be calm, peaceful, aware, mindful, balance and equanimous.
Just be yourself.
And be a good person.
To be a good lawyer/legislator, first you must be a good person.
Relax.
The Universe favors the Truth and the Truthful.
###
Manuel Laserna Jr.
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