To log in and use all the features of Khan Academy, please enable JavaScript in your browser. |-!U`&w. Kjj(-(pJ|wRrAG NA{A$3HL1Q8%_  [5] These old-growth forests contain millions of post oak from 200 to 400 years old and red cedar over 500 years old. Anonymous, Counties found in the sub-region include parts of Somervell, Erath, Hamilton, Comanche, Brown, Mills, Bosque, Hill, and McLennan counties. It is important to stay calm, because only then can you stay in control. and cookie statement. 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. The best way to prepare your expert for facing difficult questions on cross is to practice them with your experts, if appropriate. Exposed flat topped buttes and escarpments capped by Edwards limestone which have been eroded over most of the region. II. 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? The areas of ancient Cross Timbers still remaining are some of the last virgin North American hardwood forests. First, consider whether the case is likely to proceed to trial. The region features a limestone substrate as opposed to sandstone, and has greater topographical relief and denser and different vegetation than other parts of the Cross Timbers. Soils throughout the region are not uniform. 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. Or perhaps this witness will just be combative-either way, there are ways to control such witnesses effectively. Elevation increases gradually from southeast to northwest. In this study, we examined the surrounding land use matrix on the vegetation structure, composition and regeneration of six Cross Timbers forest fragments in Denton County, Texas (north of the Dallas -Fort Worth metroplex). [2] I-35 crosses this region north to south. Numerous roads cross this region, including US 70 in Oklahoma and I-20, I-30, US 67, US 81, US 82, US 180, US 183, US 281, US 287, and US 380 in Texas. We understand the importance of getting it done right. Q: In fact, you anticipated that the contract production requirements were not met, isnt that true? Sometimes experts are advocates for the parties that have retained them. The expert may provide an even more perfect setup for your next question than your question did. 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. Soils at the surface, consequently, support the growth of plants adapted to higher alkalinity, such as live oak and juniper. What does matter is getting the witnesss own words in writing into evidence before the judge. The following, adapted from the Chicago Manual of Style, 15th edition, is the preferred citation for this entry. In May of 1854, J. Pope's report on the exploration of the region for a route for the Pacific Railroad stated ".but by far the richest and most beautiful district of country I have ever seen, in Texas or elsewhere, is that watered by the Trinity and its tributaries. Test areas as to which the expert might support your case. Warren E. Platt, Cross Examination of Experts: How to Avoid Hurting You Case, Product Liability Update, (August 26, 2013), http://www.swlaw.com/blog/product-liability-update/2013/08/26/cross-examination-of-experts-how-to-avoid-hurting-your-case/. When an opposing expert is willing to render opinions favorable to your case, do not be afraid to make use of that testimony. You may be able to find information in the treatise or from one of the authors that contradicts the experts opinions. The most tornado-prone ecoregions in Texas are the Rolling Plains, the Cross-Timbers and Prairies, and the Blackland Prairies. 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. Cross Timbers oaks are used for firewood, railroad ties, and poles, but the most important function of the timber belt is preserving water. Be persistent, but polite. We are drowning in a flood of e-mails, and they are all part of e-discovery. Its market capitalization is minuscule, but its dividend is quite large. On June 19, 2014, Burger initially filed a Complaint in the United States District Court of the Southern District of Ohio. endstream endobj 2265 0 obj <>stream Cross Timbers Royalty Trust operates as an express trust in the United States. The city of Arlington, Texas lies within this zone, and Denton and Cleburne are on its eastern edge. H@O@WF A This is one of the only chances opposing counsel will have to directly poke holes in your case by attacking the credibility of your experts testimony. In others, cross is open and can be directed to any subject that is relevant even if not addressed on direct. What Are the Benefits of Having an Estate Plan? See, New Court Rules, infra. Therefore, acid rain is far too weak to negatively affect your skin in any way. In the Fort Worth Prairie and Lampasas Cut Plain, shallow soils were formed over Cretaceous limestone parent materials. endstream endobj startxref 2022 by Stange Law Firm, PC. The Trinity sands area at the east is a plain much of the surface of which is now so eroded as to forbid its use agriculturally. It passes through northwestern Grayson County, eastern Cooke, Denton and Tarrant counties, central Johnson County, western Hill County, and northern McClennan County. The Cross Timbers vary in width from five to thirty miles, and entirely cut off the communication betwixt the interior prairies and those of the great plains. "[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. When you choose us, you dont have to sacrifice quality or service. The average width of the Eastern Cross Timbers does not exceed fifteen miles, and its features disappear near the Brazos at Waco. The location of the East and West Cross Timbers was well known by these early travelers who used them as points of reference for travel. When you have prepared for hours or days to destroy an opposing expert, you become captivated by how powerful your carefully crafted outline is. Posted 6 months ago. The term Cross Timbers, also known as Ecoregion 29, Central Oklahoma/Texas Plains, is used to describe a strip of land in the United States that runs from southeastern Kansas across Central Oklahoma to Central Texas. Another strategy to handle this type of question is to say in some circumstances if that is the case. Rainfall is highly variable in this region, averaging about 25 inches in the western reaches to 35 inches in the east. Your questioning style may be open-ended like a direct examination, narrow and controlling like a cross-examination, or a combination of the two. 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. Direct link to prehistoric-rishi's post without weathering, erosi, Posted 3 months ago. Managing the Holidays After a Divorce With Children. 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. It is bordered on the east by the Blackland Prairie Ecological Region, the west by the Rolling Plains Ecological Region, and extends south and southwestward to the Llano Basin and Edwards Plateau Ecological Region in central Texas. It will be easy to get angry and frustrated with an evasive, non-responsive witness. We'll send you a couple of emails per month, filled with fascinating history facts that you can share with your friends. Made up of a mix of prairie, savanna, and woodland, it forms part of the boundary between the more heavily forested eastern country and the almost treeless Great Plains, and also . Second, within that framework, determine what you hope to accomplish through the deposition. [@5`Ol-'CfdzM"%utg'6u%kr)2t&MkW=RwR[OJ;k&M-q^RxUYO}8{H_Q5 o!M+W,/+ukk;rb]{| with let's say a small rock, sure it can take a while to break it down, but eventually the small rock will break but it won't take as long as it would for a big rock. Dyksterhuis (1948) described the Western Cross Timbers as an area "extending 150 miles south from the northern limits near the Red River, curving westward at the southern extremity. The towns of Sand Springs, Sapulpa, Ada, and Shawnee, Oklahoma fall within this large area; Bartlesville and Okmulgee lie on the eastern edge. To determine whether, if any of the facts as the expert understands them were changed, the expert would change his or her opinions. [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. 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. 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. First, do not argue with the witness. Plaintiff Ken Burger ("Burger") is an Ohio citizen who resides in Cincinnati, Ohio. Note the way to phrase the question-a true statement at the time it was written. 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. "[17] Josiah Gregg described the Cross Timbers in 1845 as varying in width from five to thirty miles and attributed their denseness to the continual burning of the prairies.[18]. Indians used the Cross Timbers as a north-south avenue that afforded secrecy from enemies. Preparation includes distilling the key points and determining how to convey them. These experts may be susceptible to being put into a box for purposes of cross-examination. Direct link to lol.lamo.hi.bye's post Rocks are left out in the, Posted 21 days ago. Even if you do nothing else while deposing an expert witness, at least make sure you confirm that the expert has told you all his or her opinions about the case. Cross Timbers' acquisition strategy has given it a sizeable portfolio of drilling prospects. Military divorces are handled, For many people, the holidays are a time of joy and happiness where the traditional obligations of work and school are put on hold, and, Aspatore Books from Thomson Reuters Westlaw. Save that effort for when you have your own expert on the stand and she is willing to cooperate in your educational endeavor. Some organizations and maps refer to the Cross Timbers ecoregion as the Central Oklahoma/Texas Plains. That can lead to a lengthy, tedious cross that does not capture the judges attention. 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. [7] In southern Oklahoma, the Cross Timbers are located on the very edge of the Great Plains, as they border directly parts of Level I Ecoregion 8.0, the Eastern Temperate Forests; elsewhere, the Cross Timbers are separated slightly from the Eastern Temperate Forests. 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. Be sure to discuss with your expert instances where I dont know is NOT an acceptable answer, such as when the question directly relates to a basis or methodology of your experts opinion. Email subscriber privacy policy 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. Texas Farm and Ranch Land Conservation Program, Wildlife Management in North Central Texas. In Oklahoma, scientists found a 500-plus-year-old red cedar and a 400-year-old post oak in Keystone Ancient . Two fragments adjacent to The region from one river to the other, is no less bountifully supplied with buffalo, bear, deer, antelope, wild boars, partridges, and turkeys. Direct link to Mark's post Acid rain is about 100 ti, Posted 2 months ago. al. A: Yes. This strategy of beating them to the punch, so to speak, will not only catch opposing counsel by surprise and weaken their strategy on cross, but will also demonstrate that you and your expert have explored any potential problems in the testimony and have addressed them to the court vis--vis a proper counter argument or explanation. 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. Discovery Litigation Services is skilled in Cross Timbers depositions and court reporting.