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DEVELOPE A FULL STORY ON DIRECT EXAMINATION

On direct examination it is important to develop as much of a complete story as possible. It also needs to be consistent with your case's theory and themes. People are going to want to know why you were there, what you were doing, and what caused the event in question.

Using reference points can add to the witness's credibility of how they remember certain details (i.e. I know it was 8 p.m. because I just got off work). A complete story might even include the witness's emotions.

Try to use open ended questions in direct examination. That way it's the witness's story and not the attorney's.

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Aaron Baghdadi

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Aaron Baghdadi