[2] It includes a small part of Love County, Oklahoma (the only part of this region outside of Texas) and passes south through western Cooke County, eastern Wise County, and western Denton, Tarrant, and Johnson counties, and also includes parts of Parker, Erath, Hood, Somervell, Hill, and McClennan counties. I am curious. Home; Projects. 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." 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. These experts may be susceptible to being put into a box for purposes of cross-examination. Exposed flat topped buttes and escarpments capped by Edwards limestone which have been eroded over most of the region. These landscape changes will have long lasting consequences for wildlife and habitat resources in this sub-region. The city of Arlington, Texas lies within this zone, and Denton and Cleburne are on its eastern edge. If the only people in the courtroom who realize how effectively you have gutted the oppositions expert are you and the expert, then the expert has won and you have lost. It holds 90% net profits interests in certain producing and nonproducing royalty and overriding royalty interest properties in Texas, Oklahoma, and New Mexico; and 75% net profits working interest in four properties in Texas and three properties in Oklahoma. Deny that the document she wrote is a true statement? A: Yes. If not, consider whether that question should be dropped or recast. [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. Soils throughout the region are not uniform. The company plans to . In essence, you are making the judge the expert. Direct link to Kayla Stout's post Is chemical or mechanical, Posted 5 months ago. Call Discovery at (855) 847-0999. Going on too long is one of the two most frequent causes of an unsuccessful cross examination. This happens through weathering, erosion, and deposition. Every dollar helps. Crow Holdings has submitted to the town of Flower Mound a site plan proposal for the Cross Timbers Business Park, a 10-building warehouse park in the northwest corner of FM 1171 and Hwy 377. Remind your witness to leave the door open for clarification on re-direct. Dan Goldman and Mor Wetzler, How to Take a Deposition, ABA Young Advocates Section of Litigation, (April 4, 2011), http://apps.americanbar.org/litigation/committees/youngadvocate/articles/spring2011-take-deposition.html/. Mr. Burger purchased and installed Decking on his home in the summer of 2010. By reading the statement into the record, you are driving home its content in a far more effective way than by just authenticating the document. 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. Q: In fact, you anticipated that the contract production requirements were not met, isnt that true? The expert may provide an even more perfect setup for your next question than your question did. PDF Texas Conservation Action Plan Cross Timbers' acquisition strategy underpins explosive rate of growth 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. Q: You knew there had been a delay in the manufacturing process, didnt you? There are two main types of weathering: mechanical and chemical. 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. 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. 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. For all yes or no questions, framing is key for both the expert and the cross-examiner. Cross Timbers Royalty Trust operates as an express trust in the United States. I. CPLR 3110 (1) A. 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. Lastly, your plan for the experts deposition may include hypothetical questions, containing facts and assumptions which you can prove at trial, that will undermine the experts opinions and ultimately win your case. The altitude of the belt is slightly higher than that of the surrounding prairies. (Diggs et. Urban sprawl and developments have rapidly extended into the sub-region as the human population to increased in the region. Your contact information is used to deliver requested updates or to access your subscriber preferences. [@5`Ol-'CfdzM"%utg'6u%kr)2t&MkW=RwR[OJ;k&M-q^RxUYO}8{H_Q5 o!M+W,/+ukk;rb]{| 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. Underlying layers of limestone slope eastward with the exposed ends of younger layers forming escarpments or "cuestas" that produce the scenic topography typical for the area. His remaining testimony is not credible because common sense tells you the document represented what was true at the time it was written. III. 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. If you can do it at trial, you can do it at a deposition, and a lot more. 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. A party will cross notice a deposition to preserve their right to conduct a deposition on issues of relevance to their position. Before taking an expert's deposition, the parties should have completed fact discovery-interrogatories answered, documents obtained, lay witnesses deposed. Deny that he wrote the document? *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= ", In 1840, Col. The Cross Timbers: The Ancient Forest at America's Crossroads Here is a typical exchange of effective use of e-mails in cross-examination: Q: Is this an e-mail that you sent on September 2, 2007? 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. Preparation includes distilling the key points and determining how to convey them. Best Winery In Grapevine. Development plans. Elevations across the region range from 500 to 1,500 feet. While looking for the places where you failed to keep the ball in play with only leading questions, look for where the cross fell apart. Cross Timbers | The Encyclopedia of Oklahoma History and Culture (see LOWER PLAINS.). It was also a formidable obstacle to travelers because of the density of growth. 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. Land use practices associated with these and other ventures created a landscape that experienced invasion and domination in some areas by problematic brush species such as mesquite, Ashe juniper and other native woody species. Every person works hard to collect different property, investments, and assets throughout their life. Most grasslands have been degraded and remain only as remnants where shallow soils prevented cultivation. endstream endobj 2267 0 obj <>stream 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. He stated, "The growth of timber is principally small gnarled, post oaks and black jacks, and in many places the traveler will find an almost impenetrable undergrowth of briers and other thorny bushes. Review your understanding of weathering and erosion in this free article aligned to NGSS standards. This way, it makes clear that your witness is not evading a difficult question, but is rather answering in the most accurate way possible. 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. Do not let an expert push you around. In fact, outcrops of the Paluxy sands are interspersed among calcareous materials to the east of the Trinity sands; without exception, the narrow belts of Paluxy sand outcrops support a growth of hardwoods, forming ribbons of woodland in an area where grasses would normally predominate. Deciding to end your marriage is never simple, especially when you know how difficult the process can be. 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. The other party only gets to cross examine the witness. How acidic is Acid Rain and how does it happen. Second, within that framework, determine what you hope to accomplish through the deposition. "F)YA`:KAls!G>;~ZO If the attorney insists on cutting off your witness, instruct your witness to answer the next question by stating the previous question was not completely or accurately answered. Judges will retain information better when they interact with that information. It will be easy to get angry and frustrated with an evasive, non-responsive witness. [3] Today, land use is a mixture of rangeland, pastures, and farmland. The diversity and configuration of plant communities on the landscape influence wildlife populations. [5] The prairie portions are chiefly tallgrass on finer, dry soils. Discovery Litigation will cover your Cross Timbers deposition. In pioneer days the woodland growth on the Trinity sands supplied fuel for settlers on the western frontier of Texas as well as timber for log houses. 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. Posted on Nov 14, 2016. Much of the land in this region is also used for livestock ranching for cattle, sheep, and goats. Crow Holdings' site plan proposal for the Cross Timbers Business Park, a 10-building warehouse park in the northwest corner of FM 1171 and Hwy 377. Is chemical or mechanical weathering more common? A broader, southern extension of the Grand Prairie, found only in Texas; it is underlain by limestone rather than sandstone, and serves as a physiological and vegetational transition to the Edwards Plateau, which it borders to the south. The choice of a lawyer is an important decision & should not be based solely upon advertisements. The natural vegetation is a woodland predominantly made up of dwarfed post oaks. The presettlement Cross Timbers are believed to have covered approximately 28,000 square miles (7,250,000 hectares), extending from central Texas across . Terms of Use | Privacy Policy Discuss different strategies of how to approach this problem with your expert witness, so important parts of testimony are not left out. For example, if a witness may not be at trial, you do not want to have that witness give responses adverse to your client; you should then be wary of open-ended questions (e.g., what happened next?). If you doubt that, go back and look over the last cross examinations you have handled. You may need to object and then move to strike portions of the experts answer. Direct link to Mahiro's post I have a river in my back, Posted 2 months ago. According to the University of Arkansas Tree Ring Laboratory, the Cross Timbers contain millions of 200- to 400-year-old post oaks, trees predating the birth of our nation and which had already lived for a century or more at the time of Washington Irving's visit to Indian Territory. hb```e``c`230 P9CLlll?9qZHx*"9p1qrxqmG\B/_8:x89vsp\==c/vq\\wUz2Ev={mnmwoIxv;D@YY .l @dp&0f X;"@ You get the resources of a large divorce and family law firm AND the attentive service of a local attorney. 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. Ignore the experts (possibly feigned) exasperation, and ask your questions. %%EOF endstream endobj 2265 0 obj <>stream Short grasses occur over much of the area in localities where the woodland growth is sparse. In others, cross is open and can be directed to any subject that is relevant even if not addressed on direct. Although habitat for wildlife is present throughout the ecological region as a whole, populations vary considerably within sub-regions. Be persistent. The terrain in most of this sub-region is very hilly, with sandstone and limestone escarpments, steep slopes, and irregular surface features. Direct link to pbro7467's post How acidic is Acid Rain a, Posted 3 months ago. Therefore, acid rain is far too weak to negatively affect your skin in any way. The Cross Timbers bands made travel difficult for settlers, yet the ecosystem provided for their basic needs. Direct link to evanlin0312's post water can melt/dissolve/b, Posted 6 months ago. Acid rain is about 100 times less acidic than Coca-Cola. 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. 0 The greater the familiarity, the greater the acceptance. lB)Onw@HO l 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. You are paying a significant amount for the deposition, so get your moneys worth. Thousands of e-mails. Early travelers through north Texas coined the name "Cross Timbers" by their repeated crossings of these timbered areas that proved to be a barrier to their travel on the open prairies to the east and west. What does matter is getting the witnesss own words in writing into evidence before the judge. While planning for your future may seem like a daunting task, When one person in a couple is in the military, their divorce may be substantially different from a traditional civil divorce. Login (855) 847-0999 calendar@huseby.com 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. 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. Post oak-blackjack oak woodlands characterize much of the West Cross Timbers. See for yourself why so many call us their reporting company. Feb 2014 Friends. What does it mean to cross-notice a deposition? - Avvo Surprisingly, however, these trees conceal their age very well. For the city in Hickory County, Missouri, see, The outline of the Cross Timbers as defined by the, Plummer, R., Narrative of the Capture and Subsequent Sufferings of Mrs. Rachel Plummer, 1839. [5] These old-growth forests contain millions of post oak from 200 to 400 years old and red cedar over 500 years old. Parker Square on Main is 0.9 miles away, and Cross Timbers Court is within a 16 minutes walk. Put the expert into a box. The Western Cross Timbers is underlain by three larger groups of geologic formations: the Trinity sands of the Comanchean or Lower Cretaceous, the hard rocks of the various Pennsylvanian formations, and the Continental Red Beds materials of the Wichita formation in the Lower Permian. Language links are at the top of the page across from the title. Schedule your Missouri/court Reporters Cross Timbers/ deposition today! 4 Y`c<6 #(@N1r 7maaX#vA Cross Timbers oaks are used for firewood, railroad ties, and poles, but the most important function of the timber belt is preserving water. Remind your expert of the role that he plays during direct examination and the litigation generally. 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. Brainstorm with your expert better ways to present this information that will keep the judge interested in your experts testimony. This is a skirt of woodlandcalled the Cross Timbers (West Cross Timbers)Whether this was once a beach of a mighty lake or a sea we must leave to the geologist to determine." Weathering and erosion (article) | Khan Academy You must elicit that information so, among other things, your own expert will be able to identify points of criticism or disagreement. Direct link to prehistoric-rishi's post without weathering, erosi, Posted 3 months ago. Our court reporters, videographers, and team members have been educated on Huseby's in-person deposition guidelines. b. Translating Expert Testimony and Legalese into Plain English. Fort Worth Prairie - In Northcentral Texas, the Fort Worth Prairie vegetative sub-region is located between the East and West Cross Timbers sub-regions, extending from western Cooke and eastern Montague counties on the north, southward to northern Edwards Plateau and includes portions of Denton, Wise, Tarrant, Parker, Johnson, and Hood counties. The point is that you must have an outline and a strategy for your deposition of an expert. Direct link to neela's post why does acid rain dissol, Posted a month ago. 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. A: Yes. Often, an expert such as a treating doctor who is not an outright advocate for the other side will concede points when appropriate. We'll send you a couple of emails per month, filled with fascinating history facts that you can share with your friends. 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. Vegetation on the landscape of the Cross Timbers and Prairies Ecological Region of Northcentral Texas has undergone significant changes over the past 150 years. The term "Cross Timbers" refers to an ecological region of woodland and forest vegetation in central and eastern Oklahoma. 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. [2] Overall, the Cross Timbers are not as arable as the surrounding ecoregions. 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. Anything else will surely land you in hot water-this witness will take advantage of any opportunity to derail your case with his version of what is important for the jury to know. 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 you plot out cross examination, go carefully through the documents, especially the e-mails. Cross Timbers APEX Accelerator at The UTA Research institute. Your conduct should always remain respectful. Hundreds of e-mails. We understand the importance of getting it done right. Whether invoking the often used recipe analogy for a patent, talking about lottery odds, or speaking about home or car loans, judges use analogies to understand the methods and reasoning used by experts because these anecdotes touch on an experience the judges themselves have had. The Arbuckle Mountains are located in a small area nestled in between regions 29g and h; it is made of folded, rather than dissected, limestone, sandstone, and dolomite, and features the greatest topographical relief of the entire Cross Timbers, though not the highest elevations. because the big rock has more volume than the small rock, the water has more atoms to break down for the big rock to be broken. You would cross-examine the witness in this type of deposition as you would at trial. 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. c. Effective Use of Evidence/Documents in Examination. hVmoH+tw Retained experts are notoriously difficult to control, particularly for a new lawyer. "[16] Rachel Plummer, while a captive of the Comanche in 1836, described it as "a range of timber-land from the waters of Arkansas, bearing a southwest direction, crossing the False Ouachita, Red River, the heads of Sabine, Angelina, Natchitoches, Trinity, Brazos, Coloradothe range of timber is of an irregular width, say 5 to 35 miles wideabounding with small prairies, skirted with timber of various kinds oak, of every description, ash, elm, hickory, walnut and mulberrythe purest atmosphere I ever breathed was that of these regions. Also, when it comes to the judges perception, you want to continue to make sure you are the one who looks credible and forthcoming. When an opposing expert is willing to render opinions favorable to your case, do not be afraid to make use of that testimony. What is the witness to do? 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. If the experts answers appear to defeat the credibility challenge posed by your questions, then you have lost and the expert has won. [2] I-35 crosses this region north to south. Having a plan of attack is key, especially with respect to the more highly technical aspects of your experts testimony. Fragmentation of wildlife habitat is also rapidly increasing in the eastern counties of the West Cross Timbers where larger land holdings are being subdivided and sold as small home building site, farms and ranchettes. 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. 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. deposition, such as using exhibits and cross-examination. Sometimes, based on a desire to please the attorney and the court, experts may get ushered into answering a line of questioning outside the scope of their expertise. It can be further subdivided into four ecological or vegetative sub-regions: East Cross Timbers, Fort Worth Prairie, Lampasas Cut Plain, and West Cross Timbers. hbbd``b`^$@$b8`v @"#"O S. Fort Worth, Texas 76118. Counties found in the sub-region include parts of Somervell, Erath, Hamilton, Comanche, Brown, Mills, Bosque, Hill, and McLennan counties. Our professionals are experienced in cases of all sizes. Ask anticipated cross-examination questions. The region has been important chiefly for its mineral resources. 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. It served as a dividing line between the hunting grounds of the Plains Indians and East Texas Indians. cross timbers deposition. 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. 2022 by Stange Law Firm, PC. 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. Discovery Litigation Services is skilled in Missouri/court Reporters Cross Timbers/ depositions and court reporting. 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. For example, instruct your witness that if there is some important portion of testimony that needs to be included, then the witness should take the liberty of saying what needs to be said. 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. Find out which treatises or authors the expert considers to be authoritative in the field. 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. They are always waiting for you to give them an opportunity to reiterate their favorite themes. Numerous U.S. |Kfpss About 17 million acres are represented by this region of alternating bands of wooded habitat scattered throughout a mostly prairie region. Posted 6 months ago. Considering all of these goals will frame whether your questioning style will be primarily like a direct examination, a cross-examination, or a combination of the two. endstream endobj 2266 0 obj <>stream Every penny counts! White-tailed deer numbers exist at or substantially above habitat potential (the ability of native habitat to support deer without sustaining long-term degradation or loss of plant species) in much of this sub-region. The most tornado-prone ecoregions in Texas are the Rolling Plains, the Cross-Timbers and Prairies, and the Blackland Prairies. Direct link to braalt02's post Yes. The ending is what everyone always takes away. So basically if I added water to rock paper scissors, I would win each of them?