EPISODE · Jan 14, 2025 · 28 MIN
62. Cross-Examination Math: Less is More, More is Less, with Tom Innes
from May the Record Reflect · host National Institute for Trial Advocacy
In Episode 62, Philadelphia trial lawyer and NITA Program Director Tom Innes introduces listeners to cross-examination math and how the idea of “less is more” increases the impact of the questions counsel poses to a witness. Control is the name of the game in cross, so Tom also shares how to shepherd witnesses through cross, why to restrict interrogatories in the phrasing of questions, and why less is even more when examining an expert. Timestamps & MoreTopics3:06 How to think about cross3:53 Objectives of cross5:05 Rules of cross-examination math 6:41 Why concision helps your finder of fact9:22 Controlling an adverse or difficult witness10:15 Cross demo14:12 Omitting the interrogatory17:00 Expert versus fact witness18:11 When to break the “cross math” rule23:26 Signoff questions Quote“Every word you put into a leading question permits the witness to decide which word they will, or they can, disagree with or work around or give you a hard time about.” Tom Innes ResourcesTom Innes (bio)Judge L. Felipe Restrepo (bio)Mary DeFusco (bio)Building Trial Skills Philadelphia (program)
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In Episode 62, Philadelphia trial lawyer and NITA Program Director Tom Innes introduces listeners to cross-examination math and how the idea of “less is more” increases the impact of the questions counsel poses to a witness. Control is the name of the game in cross, so Tom also shares how to shepherd witnesses through cross, why to restrict interrogatories in the phrasing of questions, and why less is even more when examining an expert. Timestamps & More Topics 3:06 H...
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62. Cross-Examination Math: Less is More, More is Less, with Tom Innes
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