Cross Examination Example
Cross Examination Example
Cross Examination Example
page(s); line(s)
Story-telling
1) You were at Villa Diodati on the night of June 16, 2011, isnt that right?
a. Yes (73)
2) Ghost stories were being told, correct?
a. Yes I was (78)
3) And at some point in the night, Ms. Byron told everyone to write their own ghost story
correct?
a. Yes (79)
b. Possible hearsay objection
i. Present sense impression?
ii. Not trying to find out the substance of story, just fact that it was told?
4) But before, she did that, Ms. Byron actually told one of her own stories, right?
a. Yes (78-79)
5) So you were there when Ms. Byron was telling her story, right?
a. Yes (79)
6) And when Ms. Byron was telling her story, Dr. Polidori was there too, correct?
a. Yes (73/inference)
7) So Dr. Polidori heard Ms. Byrons story then?
a. Yes (inference)
b. Possible speculation objection
i. Witness testified Dr. Polidori was there, and that Ms. Byron was telling a
storyI dont believe there is any evidence that Dr. Polidori is deaf.
8) Ms. Clairmont, while Ms. Byron was telling her story, she wasnt reading off a piece of
paper, was she?
a. No (inference)
9) She wasnt flipping through a storybook to recite the story, right?
a. No (inference)
10)In fact, it seems she was telling the story from memory, right?
a. Yes (inference)
b. (If not memory, then off the top of her head or something like that
25)And the group that night thought the Dr.s story was pretty terrible, right?
a. Yes (102)
b. Possible speculation, present sense impression?
26)Would you like to be made fun of Ms. Clairmont?
a. No (inference)
27)That would make you pretty upset, wouldnt it?
a. Yes (inference)
28)It might make you retaliate, wouldnt it?
a. Maybe
Drugs
29)Now, its your opinion Ms. Byron was high that night, right?
a. Yes she was (91-92)
30)But you didnt actually see Ms. Byron using drugs, did you?
a. No, but I could tell she was high (94)
31)So youre just guessing that she was using drugs?
a. I could tell. (94)
Relationship w/ Byron
32) Ms. Clairmont, you and Ms.Byron dont have a very good relationship do you?
a. No (55)
33)Isnt it true that you really dont like her very much?
a. No I dont like her (62)
b. (Trying to infer that she would lie because she doesnt like Byron)
34)Its your testimony today that you think she is trying to keep your child away from you,
isnt that right?
a. Yes (58-59)
35)You love your child, right?
a. Yes (inference)
36)And youve said that Ms. Byron hasnt been providing you with any child support
right?
a. She hasnt (41)
37)So you wouldnt want Ms. Byron to win this case, would you?
38)After all, you are hear testifying against her, arent you?
a. Need help with these last few, you probably see the angle Im trying to get at