Published on October 19th, 2012 | by Trey Cox0
Preparation: Index Prior Statements
No one can hope to confront a witness with his prior inconsistent testimony unless those prior statements are readily available for the attack. The most effective method of achieving the ability to instantly confront the witness with prior testimony is to have an index of all that witness has said earlier. The first rule of such an index is that the cross-examiner himself must do the indexing. An index will be a far less dangerous weapon in your arsenal if done by the hand of another. It is the very labor of indexing that gives the examiner the familiarity with the material necessary to use it instantly and capably.