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Sunday, April 17, 2011
Do You Recall Update
July 11, 2009
, I wrote that using "do you recall" in a question has its advantages. In "
Elements of Trial Practice: More than 500 Techniques and Tips for Trial Lawyers
by Peter D. Polchinski, however, he makes a valid point, particularly when examining your own witnesses: "
Avoid do you recall, do you remember, do you know or did you notice. Those headers suggest that the witness may not know the answer and they weaken the testimony.
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