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. Current Projects. Some of the areas underlain by deep sands support a growth of tall grasses. Extensive areas are still used for livestock grazing, but climax plant communities have been altered. water can melt/dissolve/break down paper, water can erode rock, and water can also rust/mildly erode scissors(plus the fact that scissors can't cut water, and the fact that paper can't catch water either) so, I guess you could. Discovery Litigation Services is skilled in Cross Timbers depositions and court reporting. Sandy loam soils are productive for agricultural crops such as peanuts, small grains, fruit trees, sorghum, pecans, and truck crops. ", Marcy (1866) stated of the Cross Timbers, "At six different points where I have passed through it (Cross Timbers), I have found it characterized by the same peculiarities; the trees, consisting principally of post-oak and blackjack, standing at such intervals that wagons can with out difficulty pass between them in any direction. Ecologically, the EPA includes the Cross Timbers as part of the vast Great Plains, which comprise Level I Ecoregion 9.0, stretching from central Alberta in Canada to northern Mexico. 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. Exposed flat topped buttes and escarpments capped by Edwards limestone which have been eroded over most of the region. The point is that you must have an outline and a strategy for your deposition of an expert. Habitat for white-tailed deer, Rio Grande turkey, bobwhite quail, mourning doves, fox squirrels, rabbits and a variety of nongame wildlife species is found here. If not, consider whether that question should be dropped or recast. Q: And that-to use your words-concerned you, isnt that true? Published by the Texas State Historical Association. Login (855) 847-0999 calendar@huseby.com Email: CrossTimbers@uta.edu. The Eastern (or Lower) Cross Timbers, a narrow band of blackjack and . If you did not ask that catchall question at the deposition and cover all of the opinions the expert has, and the expert then renders at trial opinions you were not aware of, your case could be endangered. These experts often are minimally credible, because they are unwilling to concede any point, even when the point is beyond dispute. MKulu#9315a;3CIc(@F.42D$90IdqD-1)#^ xx 6y|-&oO RFl_KnOUP)X}Plgj0JX`m#ruo%jL'}{X q1'vQ ;O=s9kHxaKh0$RWq uo8/{E'&KJpi']}q{LG? 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. Terrain of the mostly treeless vegetative region, located north of the Brazos River, is characterized by gently sloping flat surface features with thin soil over hard layers of resistant limestone. Whether you need videographer services, interpreter services, or something even more unique, we have the personnel and service culture to make your deposition as seamless as possible. Do not let the expert move from a topic if you think it has not been sufficiently addressed. [5] These old-growth forests contain millions of post oak from 200 to 400 years old and red cedar over 500 years old. In addition to not letting an expert push you around, you must be persistent in following through with your line of questions. Much of the land in this region is also used for livestock ranching for cattle, sheep, and goats. The Cross Timbers are defined by the United States Environmental Protection Agency as Ecoregion 29, a Level III ecoregion. 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). 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. 0 H|OO@)HvBBMla=v=]@=4sIFv["iARDk5O $88][D4,)rs}%(DL`_"_"qw7)Ebh@iOUm Y2+kCunCQI olW Our reporters that cover Cross Timbers are highly skilled in their craft, and they are ready to meet your specific case needs. 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. [6] More specifically, the Cross Timbers fall into Level II Ecoregion 9.4, the smaller South Central Semi-Arid Plains. You may be able to find information in the treatise or from one of the authors that contradicts the experts opinions. 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. B. Owing to the fact that the parent materials are prevailingly noncalcareous, both the soils and the natural vegetation of the Western Cross Timbers areas differ sharply from soils of adjacent areas underlain by either "hard" or "soft" formations that are also highly calcareous. Hundreds of e-mails. Acid rain is about 100 times less acidic than Coca-Cola. Topographic types in the region vary with the major geologic formations that outcrop in the area. cross timbers deposition. Home; Projects. 4 Y`c<6 #(@N1r 7maaX#vA 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. So basically if I added water to rock paper scissors, I would win each of them? %%EOF [2], No major metropolitan areas lie wholly within the Cross Timbers, although roughly the western half of the Dallas-Fort Worth Metroplex does, including the cities of Fort Worth, Denton, Arlington, and Weatherford. The other party only gets to cross examine the witness. Most of this region is underlain by various limestone formations. Comanches raided east of the Cross Timbers in the early years, and the Wichitas and others used the wood in the Cross Timbers. Elicit all the experts opinions and bases of opinions. 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." You may need to object and then move to strike portions of the experts answer. For lawyers learning how to take depositions, there are a few guiding principles to keep in mind and a number of traps to avoid. H@O@WF A they make everyone who enters the door feel like family. Parks and Recreation. About 17 million acres are represented by this region of alternating bands of wooded habitat scattered throughout a mostly prairie region. If the last area of questioning finishes off the experts credibility, you have one. Texas State Historical Association (TSHA). cross timbers deposition. Direct link to pbro7467's post How acidic is Acid Rain a, Posted 3 months ago. Leasing land for deer hunting is an important economic enterprise of the sub-region. Discuss different strategies of how to approach this problem with your expert witness, so important parts of testimony are not left out. 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. Direct link to DRAKEB's post I don't know. This field is for validation purposes and should be left unchanged. Schedule your Cross Timbers deposition today! 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. Extensive open grasslands and brushy rangelands occur in the West Cross Timbers sub-region. Elevations across the region range from 500 to 1,500 feet. 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. The ending is what everyone always takes away. Deny that the document she wrote is a true statement? Ensure that you have covered all bases for each opinion by asking catchall questions such as Are there any other bases for this opinion that you have not already mentioned? Make sure you keep asking that question until the answer is a definitive no. Then, move on. In Oklahoma, scientists found a 500-plus-year-old red cedar and a 400-year-old post oak in Keystone Ancient . ", without weathering, erosion isn't possible, so I'd say weathering. 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. Numerous U.S. More likely, confronted with the e-mails memorializing of the witnesss contemporaneous statement, the witness is bludgeoned into an admission of yes. It is very important for you to generally remain the noble person who is confronting the expert. Consequently, plant communities change dramatically within short distances resulting in different land use potential for livestock grazing, farming, wildlife management, or other uses. Most of the timber appears to be kept small by the continual inroads of the "burning prairies;" for, being killed almost annually, it is constantly replaced by scions of undergrowth; so that it becomes more and more dense every reproduction. Direct link to Mark's post Acid rain is about 100 ti, Posted 2 months ago. you may want to treat the deposition as a cross-examination . 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. Weathering occurs when water breaks down rocks and soil to create sediment. 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. 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. Website and Maintenance by Appeal Design, Court Reporting Cross Timbers, Missouri 65634. Be persistent. His remaining testimony is not credible because common sense tells you the document represented what was true at the time it was written. If a question is difficult to answer by simply stating yes or no, let your witness know it is perfectly fine to tell the questioning attorney that such a simple answer cannot be provided in that context. u+W Go|iATB5B!te=MPY ~2@Y;(JB~7@$ V! @"\X^qOy$)EG:skr cM+k]a|jA`W>rkI *i68i=.UhsMNdU2~&o r.J"~e(^MTmvAU/ 5h5 iSUg3w|I-j5X W]BZg4Hw vX$ Discovery Litigation will cover your Cross Timbers deposition. Exposed sandstone rocks and boulders dominate landscape features in many areas. If the witness says, No, I do not believe my statement was true when I wrote it, then he is admitting he is a liar. 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. Cross Timbers, The easiest way to control a witness is through the use of exhibits. [3], Geologically speaking, the Cross Timbers are underlain by Pennsylvanian and Cretaceous-era sandstone and limestone that has been moderately dissected, giving the region a gently to moderately rolling topography,[3][4] including some cuestas. Texas State Historical Association (TSHA) Judges hate repetition anyway because they are tired enough of the trial and dont want to watch the same hand played again. with let's say a sm, Posted 3 months ago. hVmoH+tw The Underwood is so matted in many places with grapevines, green-briars, etc., as to form almost impenetrable "roughs," which serve as hiding-places for wild beasts, as well as wild Indians; and would, in savage warfare, prove almost as formidable as the hammocks of Florida. There are two main types of weathering: mechanical and chemical. 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. Cross Timbers Royalty Trust (CRT) is a micro-cap, and a tiny one at thatit has a market capitalization of just $145 million. The Lampasas Cut Plain is more rugged than the Fort Worth Prairie, being bisected by numerous low buttes and mesas formed by extensive erosion during it geologic formation. Office: 817-272-5978. 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/. Sometimes experts are advocates for the parties that have retained them. I. CPLR 3110 (1) A. Toward the south the Eastern Cross Timbers belt spans the ninety-seventh meridian from the Red River to the Brazos River. Portions of the Trinity sands area are now important in peanut culture as well as for the growing of small fruits. 26 Downer Avenue Campbelltown SA 5074; Best Winery In Grapevine. Its location was well known and served as a landmark reference for travelers. 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. In most jurisdictions, re-direct is limited to matters that were covered on cross. You are paying a significant amount for the deposition, so get your moneys worth. About CRT. "Acid rain is caused by the release of sulfur dioxide and nitrogen oxides into the atmosphere, where they react with water, oxygen, and other chemicals to become sulfuric and nitric acid respectively. endstream endobj 2262 0 obj <>/OCGs[2274 0 R]>>/Pages 2246 0 R/StructTreeRoot 450 0 R/Type/Catalog>> endobj 2263 0 obj <>/Font<>/ProcSet[/PDF/Text]/XObject<>>>/Rotate 0/Type/Page>> endobj 2264 0 obj <>stream Ask open-ended questions that will allow the expert to elaborate on the most important points of testimony. Remind your expert not to get defensive if they feel attacked by a line of questioning. Washington Irving, in 1835, described it as "like struggling through forests of cast iron. Coca-Cola is not strong enough to dissolve skin. The risk of extensive preparation is the tendency to show the judge all that you know. 26 Downer Avenue Campbelltown SA 5074; hbbd``b`^$@$b8`v @"#"O Most grasslands have been degraded and remain only as remnants where shallow soils prevented cultivation. I have a river in my backyard and when the rainwater evaporates i can see the dirt that got eaten at by the rain :^. WHAT DOES AN IN-PERSON DEPOSITION LOOK LIKE? Post oak-blackjack oak woodlands characterize much of the West Cross Timbers. The diversity and configuration of plant communities on the landscape influence wildlife populations. No matter how many times an expert has testified at trial, being grilled during cross-examination is always incredibly stressful. There is nothing gained by appearing to become angry and frustrated by the experts unwillingness to concede points that she should obviously concede. You must be clear about the purpose of your deposition. Direct link to Mahiro's post I have a river in my back, Posted 2 months ago. Indians used the Cross Timbers as a north-south avenue that afforded secrecy from enemies. 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." It almost doesnt matter what the witnesss response is. 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. This is significant, since bias is a valid grounds for disqualifying an expert witness. Remind your witness to leave the door open for clarification on re-direct. Direct link to lol.lamo.hi.bye's post Rocks are left out in the, Posted 21 days ago. Austin: University of Texas Press, United States Environmental Protection Agency, "Ecological Regions of North America Level I", "Ecological Regions of North America Level I-II", "Descriptions of the Level IV Ecoregions of Texas", "TPWD: An Analysis of Texas Waterways (PWD RP T-3200 1047) Brazos River", "Brazos River Canyonlands The Brazos River", Texas counties map showing the ecoregion; similar to the above map. and cookie statement. In some places, however, the oaks are of considerable size, and able to withstand the conflagrations. The Cross-Timbers region of the United States, situated in the southern Great Plains along the western edge of the eastern deciduous forest, was historically Quercus-dominated open forest interspersed with tallgrass prairie and shrubs communities. The objective is to cast significant doubt on the credibility of the expert. A: Yes. 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 . Discover 4 parks within 8.3 miles, including Lewisville Lake Environmental Learning Area, Coppell Nature Park, and Coppell Community . Do not let an expert push you around. If the case goes to trial, usually only a very small part of the deposition is ever used. Call Discovery at (855) 847-0999. Although the exact approach is a matter of style, it is usually better to use a general outline for a deposition than a detailed list of every expected question. It is important to stay calm, because only then can you stay in control. Early travelers called this region the Monte Grande (Grand Forest) and later the Lower Timbers. 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. Find out which treatises or authors the expert considers to be authoritative in the field. [9][10][12], Coal mining has historically been an important activity, as bituminous coal deposits are found throughout the region;[13] indeed, the town of Newcastle in Young County was named after the English city of the same name due to the coal connection. You may learn the expert considers your experts work to be authoritative, or that the expert considers a treatise in which your expert is published to be authoritative.
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