Direct Exam of _________________________ Fact to get into evidence • What do we need this witness to say? Is exhibit needed? Relevance • Why is this evidence relevant to your case? Hearsay • Could this evidence raise a hearsay objection? • If so, what will the objection be? Exception/Not Hearsay • Why is this evidence not hearsay or is there an exception that applies? Foundation • What is the foundation (if any) that you need to lay before asking the witness about this? What is the best way to ask this question?
Fact to get into evidence • What do we need this witness to say? Is exhibit needed? Relevance • Why is this evidence relevant to your case? Hearsay • Could this evidence raise a hearsay objection? • If so, what will the objection be? Exception/Not Hearsay • Why is this evidence not hearsay or is there an exception that applies? Foundation
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What is the foundation (if any) that you need to lay before asking the witness about this? What is the best way to ask this question?
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