Assume that on direct examination, Dan Jones testifies that he did not sell any wine to
anyone between 9:00pm and 10:00pm on June 5, 2016.
1) Commit
a. Mr. Jones you said something a moment ago that really stuck
out to me.
b. It is your testimony today that you did not sell any wine to anyone
between 9:00pm and 10:00pm on June 5, 2016.
2) Credit
a. You testified previously in this case.
b. You were deposed
c. In that deposition you told the truth
d. The whole truth
e. And nothing but the truth
f. You signed that statement under the penalty of perjury
3) CONFRONT
a. Let the record reflect I am now opening that signed transcript of your previous
testimony
b. Directing the court and opposing counsel to page 3 of the witness’s previous
testimony.
c. Mr. Jones please go to the e binder and direct your attention to pg 3 your
previous testimony.
d. Now, please read silently as I read allowed. I did sell a bottle of inexpensive
wine to a gentleman within ten or fifteen minutes of the investigator
coming into the store that might have been Watkins.
Assume that on direct examination, Dan Jones testifies that Walter Watkins was never
a customer at Cut-Rate Liquor store.
4) Commit
a. Mr. Jones you said something a moment ago that really stuck
out to me.
b. It is your testimony today that Walter Watkins was never a customer at Cut Rate
Liquor
c. You testified previously in this case.
d. You were deposed
e. In that deposition you told the truth
f. The whole truth
g. And nothing but the truth
h. You signed that statement under the penalty of perjury
5) CONFRONT
a. Let the record reflect I am now opening a transcript of the witness’s deposition
b. Directing the court and opposing counsel to page ___ line(s)____ of the witness’s
previous testimony.
c. Mr. Jones please go to the e binder and direct your attention to pg___ line___ of
your previous testimony.
d. Now, please read silently as I read allowed. ___________________ (move on)
Assume that on cross-examination, Dan Jones admits he sold wine to a customer
within ten or fifteen minutes of Officer Bier coming into the store, but denies that the
man was a “little disheveled.”
6) Commit
a. Mr. Jones you said something a moment ago that really stuck
out to me.
b. It is your testimony today that the man was not a little dishevleled
7) Credit
a. You testified previously in this case.
b. You were deposed
c. You told the truth in that deposition
8) CONFRONT
a. Let the record reflect I am now opening that the witness’s previous testimony
b. Directing the court and opposing counsel to page 3 of the witness’s deposition
c. Mr. Jones please go to the e binder and direct your attention to pg___ line___ of
your previous testimony.
d. Now, please read silently as I read allowed. ___________________ (move on)
1) Commit
a. It is your testimony today that you suffer from an impairment
i. An impartment that makes you unable to smell
2) Credit
a. You testified previously in this case
b. You swore that testimony was true and correct
c. You swore to tell the truth
i. The whole truth
d. And Leave nothing out
e. That testimony was complete and accurate
3) Confront
a. Let the record reflect I am now opening a transcript of Dan Jones’ deposition
b. Directing opposing counsel to view the witness’s prior testimony in its entirety
c. Mr. Jones please go to the e-binde and direct your attention to the transcript
of your deposition
d. Now, Show us in you previous testimony where you said that you have an
impairment that makes you unable to small