CROSS-EXAMINATION MADE SIMPLE (Volume I): FUNDAMENTAL RULES
- Michael J. DeBlis III, Esq.

- Aug 8
- 2 min read
Updated: Aug 12

This ebook will provide you with creative tools for conducting cross-examination. From achieving basic witness control to becoming more in tune to the subtle nuances of space and proximity in the courtroom and how to use these to your advantage, I share with you some of the lessons that I’ve learned over the last two decades as a criminal defense attorney. Ironically, some of the things that we as lawyers overlook or only address in passing can be just as important, if not more, than the things that we spend the most time preparing. This ebook will reduce these techniques to simple, easy to apply rules that can be referred to before and during trial preparation.
Topics:
1. How does the author differentiate between viewing an adverse witness as an enemy combatant versus a puppy that needs training?
2. In what ways does the approach to cross-examination described in the document aim to maintain the attorney's credibility with the jury?
3. Can you explain the significance of storytelling in the context of cross-examination as outlined in the document?
4. What are the key principles that the author believes should guide an attorney during cross-examination?
5. How does the author suggest attorneys should handle emotional witnesses during cross-examination?
6. In what situations does the author believe it may be appropriate to ask open-ended questions during cross-examination?
7. What techniques does the author propose for maintaining control over a witness during cross-examination?
8. How does the author advise attorneys to select specific factual goals when conducting cross-examination?
9. Can you describe the importance of primacy and recency in structuring cross-examination questions?
10. What role does patience play in effective cross-examination, according to the author?
11. How does the author suggest attorneys should prepare for the potential harm that could arise from a witness's damaging testimony?
12. What strategies does the document provide for effectively impeaching a witness during cross-examination?
13. How does the author recommend attorneys build chapters in their cross-examination to enhance storytelling?
14. In what ways does the author emphasize the necessity of being jury-centered during cross-examination?
15. What are the potential consequences of rushing through cross-examination as highlighted in the document?




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