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Here is a suggested sequence for your cross-examination
- Gain concessions. Gain concessions before attacking, If the witness concedes every point you want from the witness. Sit down . Do not impeach.
- Show impossibility or improbability.
- Show poor perceptive skills.
- [Note that these first three approaches neither confront nor impeach the witness.]
- Impeach with Bias or Prejudice.
- Impeach for lack of qualifications
- Impeach with conflicting statements.
- Impeach with convictions.
- Impeach by demonstrating lies on a material point.
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