Relentless Criminal Cross-Examination
Table of Contents
Chapter 1Governing Principles and Strategies
I.The Law of Cross-Examination
A.Right to Confrontation
§1:01A Brief History
§1:02Rights of the Witness
§1:03Rights of Alleged Sexual Assault Victim
§1:04Denial of Right to Cross-Examine
B.Scope of Examination
§1:05Cross-Examination Limited to Scope of Direct
§1:06Scope of Redirect and Re-Cross
C.Trial Not Designed to Be Fair to Government
§1:07Government Entitled to FairOpportunityto Prove Guilt
§1:08Constitution Frames Trial in Favor of Defendant
§1:09Make Judge Understand “Fairness” Distinction
[§1:10 Reserved]
II.Initial Hurdles
§1:11For Defense, It’s All About Cross-Examination
§1:12Overcoming Defense Attorney Credibility Deficit
§1:13Controlling Your Client
[§1:14 Reserved]
III.First Rule of Cross-Examination: Do No Harm
§1:15Purpose of Cross: Persuade Jury Government Has Not Met Its Burden
§1:16Prepare Tactical, Goal-Oriented Cross
§1:17Never Ask Open-Ended Questions
[§§1:18-1:19 Reserved]
IV.What Does Not Work
§1:20Unstructured Cross
§1:21Nasty Cross
§1:22Restricting Witness to “Yes” or “No”
§1:23Appealing to Judge for Help
[§1:24 Reserved]
V.Imposing Your Will on the Witness
A.Use Police Report to Hog-Tie Officer
§1:25The Answer Is in the Documents
§1:26Police Report Not Objective
§1:27Pattern Cross: Pressure to Draft Comprehensive Report
§1:28Pattern Cross: Officer Backpedals From Report
[§1:29 Reserved]
B.Investigate
§1:30Visit the Scene
§1:31Pattern Cross: Crime Scene Details
[§§1:32-1:34 Reserved]
C.Plan Your Cross-Examination and Stick With the Plan
§1:35Difficult Witnesses
§1:36Categorize Witnesses
§1:37Witnesses You Want to Destroy
§1:38Witnesses Who May Provide Favorable Testimony
§1:39Stick With Your Plan
D.Tone, Tempo, Tenor
§1:40Tone
§1:41Tempo
§1:42Tenor
E.Extracting Favorable Evidence
§1:43What Do You Know About the Witness?
§1:44Pattern Cross: Make Defense Witness Your Own
[§1:45 Reserved]
F.Size Up the Witness (He Will Be Sizing You Up)
§1:46Good Cross Depends on Skill, Not Luck
§1:47Practical Tips for Watching the Witness
§1:48Witness Sizes You Up
§1:49Expose Officer for Behavior Outside Presence of Jury
G.Keep Questions Short
§1:50Leave No Room for “Misinterpretation”
§1:51Example: What Can Go Wrong
§1:52Example: How to Do It Right
H.Impeachment
§1:53Annotate Your Outline With References to Documents
§1:54Copy Witness’s Precise Language on Cross
§1:55Note Every Enhancement of Witness’s Story
[§§1:56-1:59 Reserved]
VI.Dealing With the Prosecutor
§1:60Objections and Jurors
§1:61Resist Temptation to Object
§1:62Objection-Happy Prosecutors
§1:63Punish Prosecutor for Signaling Witness
§1:64Play With Prosecutor’s Toys
[§1:65 Reserved]
VII.Dealing With the Judge
§1:66Judge’s Apparent Authority
§1:67In Reality, Trial Judge Has Limited Powers
§1:68Power to Hold You in Contempt
§1:69Never Allow the Judge to Intimidate You – Intimidate Him
Chapter 2Cross-Examination: Theory of Case, Opening Statement, Closing Argument
I.Develop Theory of Case
§2:01Purpose of Case Theory
§2:02Begin with Basic Chronology
[§§2:03-2:04 Reserved]
II.Opening Statement
A.Goals of Opening Statement
§2:05Tell Defendant’s Story; Shape Perceptions
§2:06Persuade With Detailed Factual Account
B.Obstacles to Success
§2:07Fear of Unreliable Witnesses
§2:08Fear of Unreliable Defendants
§2:09Fear of Conceding Facts
§2:10Fear of Unfulfilled Promises
C.Keys to Success
§2:11Resist Temptation to Play it Safe
§2:12Tell the Story Without Committing Yourself to Calling Witnesses
§2:13Cite Specific Reasons for Distrusting Government Witnesses and Prosecutor
D.Lay Foundation for Cross-Examination
§2:14Detail Inconsistent Statements
§2:15Show Witness’s Allegations to be Inconsistent With Facts
§2:16Call Attention to Witness’s Demeanor
§2:17Attack in Both Directions: Plant Seed of Suspicion About Prosecutor
E.Sample Opening Statement
§2:18Key Facts
§2:19Strategy
§2:20Sample Opening Statement
[§§2:21-2:29 Reserved]
III.Closing Argument
A.Governing Principles
§2:30General Rule: Even a Great Closing Will Not Save a Lost Case
§2:31Caveat: Closing Matters in Close Cases
B.Educate Jurors on Their Roles
§2:32Deliberations Not a Search for “Truth”
§2:33Government Must Satisfy People of Accused’s Guilt
§2:34Sample Language for Closing
C.Demonstrate Emotional Commitment to Your Client
§2:35Entrust Jury With Protecting Defendant
[§§2:36-2:39 Reserved]
D.Arm “Your” Jurors With Tools to Prevail During Deliberations
1.Help Jurors Overcome Fear of Law Enforcement
§2:40Officers Not Above Lying on Stand
§2:41Sample Language for Closing
2.Explain “Beyond a Reasonable Doubt”
§2:42Judge’s Oral Instructions Offer Little Guidance
§2:43Provide Own Definition of “Reasonable Doubt”
§2:44Sample Language for Closing
3.Show Jury How to Apply “Beyond a Reasonable Doubt”
§2:45Apply Standard to Each Piece of Evidence
§2:46Sample Language for Closing
E.Cross-Examination and Prosecutor’s Closing
§2:47If Prosecutor Gets Last Word
§2:48Don’t Just Anticipate Prosecutor’s Closing, Derail It
§2:49Caution: Calling Defense WitnessesGives Prosecutor WayOut
FORMS
Form 2-AMotion for Order Prohibiting Prosecutor From Commenting on Defendant’s Decision Not to Testify
Form 2-BSample Closing Argument — Good v. Evil
Chapter 3Cross-Examination of Arresting Officer: Motions to Suppress
I.Governing Principles
§3:01All-Too-Common Fact Pattern
§3:02Brazen Police Officers and the Forfeiture of Freedom
§3:03Judge Is Likely Just Another Frightened Citizen
§3:04Culture of Testilying
§3:05Basic Strategy for Suppression Hearings
§3:06Sample Open-Ended Cross-Examination
[§§3:07-3:09 Reserved]
II.Was Defendant in Custody?
A.Meaning of “In Custody”
§3:10Prosecutor’s Direct Examination
§3:11Defense Cross-Examination
B.Client Free to Leave House Surrounded by Armed Police
§3:12Sample Fact Pattern
§3:13Strategy
§3:14Cross-Examination
C.Suspect Voluntarily Accompanied Police to Station
§3:15Key Facts
§3:16Strategy
§3:17Angles of Attack
§3:18Cross-Examination
[§§3:19-3:24 Reserved]
III.Motor Vehicle Stops and Searches
A.Motor Vehicle Stops
1.Suspected Drug Deal in Vehicle
§3:25Common Fact Pattern
§3:26Prosecutor’s Direct Examination of Officer
§3:27Defense Cross-Examination
2.Casing the Neighborhood
§3:28Common Fact Pattern
§3:29Strategy
§3:30Angles of Attack
§3:31Cross-Examination
3.Suspected Stolen Car
§3:32Strategy
§3:33Sample Fact Pattern
§3:34Angles of Attack
§3:35Cross-Examination
[§§3:36-3:39 Reserved]
B.Motor Vehicle Searches
1.Based on Odor of Marijuana
§3:40Strategy
§3:41Angles of Attack
§3:42Cross-Examination
2.Search of Trunk Based on Odor of Marijuana
§3:43Common Fact Pattern
§3:44Cross-Examination
3.Search Based on Strong Odor of Marijuana, But Suspect Not High
§3:45Strategy
§3:46Angles of Attack
§3:47Cross-Examination
4.Search Based on Furtive Movements
§3:48Strategy
§3:49Angles of Attack
§3:50Cross-Examination
[§§3:51-3:54 Reserved]
IV.Drug Cases
§3:55Strategy: Hand-to-Hand Drug Deal
§3:56Angles of Attack
§3:57Cross-Examination
[§§3:58-3:59 Reserved]
V.Search Warrants
A.Failure to Include Evidence
§3:60Strategy
§3:61Cross-Examination
B.Confidential Informants
§3:62Strategy
§3:63Angles of Attack
§3:64Cross-Examination
[§§3:65-3:69 Reserved]
VI.Search Incident to Arrest
§3:70Strategy
§3:71Angles of Attack
§3:72Cross-Examination
FORMS
Form 3-AMotion to Suppress Statements; Unlawful Detention.
Form 3-BMotion to Suppress – Motor Vehicle Stop and Search; Drug Deal
Form 3-CMotion to Suppress – Warrant Obtained by Pretext
Chapter 4Cross-Examination of Detective Who Obtained Confession
I.Interrogation Tactics—Overview
§4:01A Single Suspect
§4:02Multiple Suspects
II.Expose Coercive Tactics
A.Detectives Have Only One Chance to Question Suspect
§4:03Strategy
§4:04Pattern Cross
[§4:05 Reserved]
B.Using Ticking Clock to Make Suspect Feel Desperate
§4:06Common Fact Scenario
§4:07Strategy
§4:08Angles of Attack
§4:09Pattern Cross
[§4:10 Reserved]
C.Detectives Need Confession Because Forensic Evidence Is Unknown
§4:11Key Facts
§4:12Angles of Attack
§4:13Pattern Cross
[§4:14 Reserved]
D.Isolating the Suspect
§4:15Strategy
§4:16Key Facts
§4:17Angles of Attack
§4:18Pattern Cross
[§4:19 Reserved]
E.Right to Make Telephone Call
1.Police Claim Defendant Not Under Arrest or in Custody
§4:20Angles of Attack
§4:21Pattern Cross
2.Police Did Not Offer Defendant Use of Telephone Following Arrest
§4:22Angles of Attack
§4:23Pattern Cross
[§4:24 Reserved]
F.Failure to Record Defendant’s Statement
§4:25Strategy
§4:26Angles of Attack
§4:27Pattern Cross
[§§4:28-4:29 Reserved]
G.Written Statement Is Invalid
§4:30Strategy
1.Detective Drafted Statement
§4:31Angles of Attack
§4:32Pattern Cross
2.Defendant’s Signature Is Meaningless
§4:33Strategy
§4:34Angles of Attack
§4:35Pattern Cross
FORMS
Form 4-AMotion to Suppress – Confession
Form 4-BMotion re Seminars Attended by Detectives Involved in Taking Defendant’s Statement
Chapter 5Cross-Examination of Informants and Accomplices
I.Governing Principles
II.The “Innocent Bystander”
A.Tie “Bystander” to Crime
§5:01Strategy
§5:02Key Facts
§5:03Angles of Attack
§5:04Cross-Examination
B.Distance “Bystander” From Client
§5:05Strategy
§5:06Key Facts
§5:07Angles of Attack
§5:08Cross-Examination
C.“Bystander” Desperate to Avoid Being Caught
§5:09Strategy
§5:10Key Facts
§5:11Angles of Attack
§5:12Cross-Examination
[§§5:13-5:19 Reserved]
III.The Consummate Liar
§5:20Strategy
§5:21Key Facts
§5:22Angles of Attack
§5:23Cross-Examination
[§§5:24-5:29 Reserved]
IV.The Desperate Witness
A.The Miscreant Co-Defendant
§5:30Strategy
§5:31Angles of Attack
§5:32Cross-Examination
[§§5:33 Reserved]
B.The Innocent Bystander/Accomplice
§5:34Key Facts
§5:35Angles of Attack
§5:36Cross-Examination
[§§5:37 Reserved]
C.The Wealthy Defendant
§5:38Key Facts
§5:39Strategy
§5:40Angles of Attack
§5:41Cross-Examination
[§§5:42-5:49 Reserved]
V.The Prison Informant
§5:50Strategy
§5:51Common Fact Pattern
§5:52Angles of Attack
§5:53Cross-Examination
[§§5:54-5:59 Reserved]
VI.The Recanting Informant
§5:60Common Fact Pattern
§5:61Strategy
§5:62Angles of Attack
§5:63Cross-Examination
Chapter 6Cross-Examination of Eyewitnesses
I.Attack Conditions Under Which Victim Made Initial Observation
§6:01Governing Principles
§6:02Strategy
§6:03Angles of Attack
§6:04Cross-Examination
[§§6:05-6:09 Reserved]
II.Initial Description Does Not Match Defendant
§6:10Strategy
§6:11Key Facts
§6:12Angles of Attack
§6:13Cross-Examination
[§§6:14-6:19 Reserved]
III.Failure to Select Client’s Photograph
§6:20Strategy
§6:21Key Facts
§6:22Angles of Attack
§6:23Cross-Examination
[§§6:24-6:29 Reserved]
IV.Photo Array
§6:30Strategy
A.Failure to Conduct Line-Up
§6:31Key Facts
§6:32Angles of Attack
§6:33Cross-Examination
[§6:34 Reserved]
B.Using Photograph Unlike Others
§6:35Key Facts
§6:36Angles of Attack
§6:37Cross-Examination
[§§6:38-6:44 Reserved]
V.Line-Up Identification
§6:45Strategy
§6:46Key Facts
§6:47Angles of Attack
§6:48Cross-Examination
[§§6:49-6:54 Reserved]
VI.Threaten to Test Witness’s Recollection
§6:55Strategy
§6:56Key Facts
§6:57Angles of Attack
§6:58Cross-Examination
[§§6:59-6:64 Reserved]
VII.Juxtaposing Witnesses
§6:65Strategy
§6:66Key Facts
§6:67Angles of Attack: Eyewitness
§6:68Cross-Examination of Eyewitness
§6:69Angles of Attack: Officer
§6:70Cross-Examination of Officer
FORMS
Form 6-AMotion to Suppress Identification
Form 6-BMotion for Access to Mug Shot Books Reviewed by Alleged Witnesses
Chapter 7Cross-Examining Expert Witnesses
I.Basic Principles
§7:01Do I Need to Cross-Examine This Expert?
§7:02Hire Your Own Expert
[§§7:03-7:04 Reserved]
II.Government’s Hired Expert
§7:05Strategy
A.“After-the-Fact” Expert
§7:06Strategy
§7:07Cross-Examination
B.Expert’s Fees
§7:08Strategy
§7:09Cross-Examination
C.Expert Testimony Is Competitive Business
§7:10Strategy
§7:11Cross-Examination
D.Defuse Prosecution’s Attack on Your Expert
§7:12Strategy
§7:13Cross-Examination
E.Bias
§7:14Strategy
§7:15Cross-Examination
F.Testifying for Defense Once or Twice Does Not Make Expert “Independent”
§7:16Strategy
§7:17Cross-Examination
[§§7:18-7:24 Reserved]
III.Government Payroll Experts
A.State Chemists/Toxicologists
§7:25Governing Principles
§7:26Strategy
1.Possible Contamination of Sample
§7:27Angles of Attack
§7:28Cross-Examination
2.Failed Confirmation of Screening Test
§7:29Angles of Attack
§7:30Cross-Examination
3.Building Up Reliability of Negative Tests
§7:31Strategy
§7:32Example: Poor Cross-Examination Using General Questions
§7:33Better Example: Strong Cross Using Specific Questions
[§§7:34-7:39 Reserved]
B.Medical Examiner
1.Governing Principles
§7:40Not Your Typical Expert
§7:41Autopsy Purpose & Procedures
2.Bullet Wounds
§7:42Strategy
§7:43Cross-Examination
3.Victim Did Not Suffer
§7:44Key Facts
§7:45Angles of Attack
§7:46Cross-Examination
[§§7:47-7:49 Reserved]
4.Poisoning
a.As Means of Murder
§7:50Difficult to Prove
§7:51Strategy
§7:52Angles of Attack
§7:53Cross-Examination
b.Physical Effects of Poison
§7:54Strategy
§7:55Key Facts
§7:56Angles of Attack
§7:57Cross-Examination
[§§7:58-7:59 Reserved]
5.Death by Natural Causes
§7:60Example: Ineffective Cross-Examination
§7:61Example: Effective Cross-Examination
[§§7:62-7:64 Reserved]
C.Accident Reconstructionist
1.Governing Principles
§7:65Little Formal Education or Training
§7:66Subjective Component to Accident Reconstruction
2.Conclusions Conflict With Witnesses
§7:67Strategy
§7:68Angles of Attack
§7:69Cross-Examination
3.Shenanigans With Measurements
§7:70Strategy
§7:71Cross-Examination
4.Motive for Revising Analysis
§7:72Strategy
§7:73Angles of Attack
§7:74Cross-Examination
[§§7:75-7:79 Reserved]
5.Misleading Clues
a.Vehicle Did Not Brake
§7:80Strategy
§7:81Cross-Examination
b.Differentiating Between Yaw Mark and Skid Mark
§7:82Strategy
§7:83Angles of Attack
§7:84Cross-Examination
6.Auto/Pedestrian Cases
§7:85Key Facts
§7:86Angles of Attack
§7:87Cross-Examination — Challenge Expert’s Ultimate Conclusions
§7:88Cross-Examination — Raise Visibility Issues
§7:89Cross-Examination — Additional Grounds for Attack
IV.Expert—Fingerprint Evidence
A.Governing Principles
§7:90Latent Prints and AFIS
§7:91Error Rate
§7:92Junk Science?
§7:93For Defense Counsel: Two Options
[§7:94 Reserved]
B.Expert Compared Latent Print With Client’s Print Only
§7:95Strategy
§7:96Angles of Attack
§7:97Cross-Examination
C.Downplaying Accuracy of AFIS
§7:98Strategy
§7:99Cross-Examination
D.Poor Quality of Latent Print
§7:100Strategy
§7:101Angles of Attack
§7:102Cross-Examination
E.Galton Points Standards
§7:103Strategy
§7:104Cross-Examination
FORMS
Form 7-AMotion for Sources Consulted by Trooper in Analyzing Accident and Drafting Accident Reconstruction Report
Chapter 8Cross-Examination in Sexual Assault Cases
I.Governing Principles
§8:01Not for the Faint of Heart
§8:02Length of Examination
§8:03Tone of Cross-Examination
§8:04The Crying Witness
[§8:05 Reserved]
II.The Alleged Child Victim
A.The Child Witness
1.Governing Principles
§8:06Establish Connection With Child
§8:07Show How Children Are Easily Led
§8:08Focus on Details
[§8:09 Reserved]
2.Failure to Inform Parents
§8:10Strategy
§8:11Key Facts
§8:12Angles of Attack
§8:13Cross-Examination
[§8:14 Reserved]
3.Failure to Tell Teacher
§8:15Strategy
§8:16Angles of Attack
§8:17Cross-Examination
B.Officer Who Conducted Initial Interview
§8:18Strategy
§8:19Key Facts
§8:20Angles of Attack
§8:21Cross-Examination
[§§8:22-8:24 Reserved]
III.The Alleged Rape Victim
A.Consent Defense
§8:25Governing Principles
1.Dressing to Attract Attention
§8:26Strategy
§8:27Angles of Attack
§8:28Cross-Examination
[§8:29 Reserved]
2.Actions That Suggest Consent
§8:30Strategy
§8:31Key Facts
a.Alleged Victim Asked About the Accused
§8:32Angles of Attack
§8:33Cross-Examination
b.Alleged Victim Approached the Accused
§8:34Angles of Attack
§8:35Cross-Examination
c.Alleged Victim Consumed Too Much Alcohol
§8:36Angles of Attack
§8:37Cross-Examination
d.Alleged Victim Let Defendant Remove Her Clothes
§8:38Angles of Attack
§8:39Cross-Examination
[§§8:40-8:44 Reserved]
B.Failure to Report Attack
§8:45Strategy
§8:46Key Facts
1.Failure to Call Police Morning After
§8:47Angles of Attack
§8:48Cross-Examination
2.Failure to Contact Police After Hospital Examination
§8:49Strategy
§8:50Angles of Attack
§8:51Cross-Examination
3.Failure to Tell Friends and Family
§8:52Angles of Attack
§8:53Cross-Examination
[§§8:54-8:59 Reserved]
IV.Story Seems to Change
A.“Fresh Complaint” Witnesses
§8:60Strategy
§8:61Key Facts
§8:62Angles of Attack
§8:63Cross-Examination
[§8:64 Reserved]
B.Confronting Alleged Victim With Inconsistent Statements
§8:65Strategy
§8:66Key Facts
§8:67Angles of Attack
§8:68Cross-Examination
[§§8:69-8:74 Reserved]
V.Emergency Room Nurse/Physician
§8:75Governing Principles
A.Decision to Conduct Sexual Assault Examination
§8:76Strategy
§8:77Angles of Attack
§8:78Cross-Examination
B.Completing Sexual Assault Forms
§8:79Angles of Attack
§8:80Cross-Examination
C.If No Evidence Connects Accused to Crime
§8:81Strategy
§8:82Angles of Attack
§8:83Cross-Examination
D.If No Injuries Found
§8:84Angles of Attack
§8:85Cross-Examination
E.Attempts to Document Injury to Vagina—None Found
§8:86Strategy
§8:87Angles of Attack
§8:88Cross-Examination
[§§8:89-8:94 Reserved]
VI.Motive for Making False Accusation
§8:95Strategy
A.Scenario #1 – To Save Face
§8:96Key Facts
§8:97Angles of Attack
§8:98Cross-Examination
[§8:99 Reserved]
B.Scenario #2 – To Deflect Allegations of an Affair
§8:100Key Facts
§8:101Angles of Attack
§8:102Cross-Examination
[§8:103 Reserved]
C.Scenario #3 – Revenge; Ignorance of Law
§8:104Key Facts
§8:105Angles of Attack
§8:106Cross-Examination
[§8:107 Reserved]
D.Scenario #4 – Desire to Break Up a Marriage
§8:108Key Facts
§8:109Angles of Attack
§8:110Cross-Examination
Forms
Form 8-AMA Rape Kit Form
Chapter 9Cross-Examination in DWI Cases
I.Governing Principles
II.Cross-Examination of Arresting Officer
A.Initial Observations of Driving
1.Good Driving
§9:01Strategy
§9:02Angles of Attack
§9:03Cross-Examination
[§9:04 Reserved]
2.Absence of Drunk Driving “Red Flags”
§9:05Strategy
§9:06Angles of Attack
§9:07Cross-Examination
[§§9:08-9:09 Reserved]
B.Bloodshot or Glassy Eyes
§9:10Strategy
§9:11Angles of Attack
§9:12Cross-Examination
[§§9:13-9:14 Reserved]
C.Odor of Alcohol
§9:15Strategy
§9:16Angles of Attack
§9:17Cross-Examination
[§§9:18-9:19 Reserved]
D.Field Sobriety Tests
1.Horizontal Gaze Nystagmus
§9:20Strategy
§9:21Angles of Attack
§9:22Cross-Examination
[§§9:23-9:24 Reserved]
2.Heel-to-Toe
§9:25Strategy
§9:26Angles of Attack
§9:27Cross-Examination
[§§9:28-9:29 Reserved]
3.One-Leg-Stand Test
§9:30Strategy
§9:31Angles of Attack
§9:32Cross-Examination
[§§9:33-9:34 Reserved]
4.Alphabet Test
a.Client Passed Test
§9:35Strategy
§9:36Angles of Attack
§9:37Cross-Examination
[§§9:38-9:39 Reserved]
b.Client Failed Test – English Is Second Language
§9:40Strategy
§9:41Angles of Attack
§9:42Cross-Examination
[§§9:43-9:44 Reserved]
E.No “Red Flags” in Defendant’s Behavior
§9:45Strategy
§9:46Angles of Attack
§9:47Cross-Examination
[§§9:48-9:49 Reserved]
F.Hospital Testing
§9:50Strategy
§9:51Angles of Attack
§9:52Cross-Examination
[§§9:53-9:54 Reserved]
III.Breathalyzer Expert
A.Police Not Entrusted With Real Toxicology Equipment
§9:55Strategy
§9:56Angles of Attack
§9:57Cross-Examination
[§§9:58-9:59 Reserved]
B.Breathalyzer Tests Air, Not Blood
§9:60Strategy
§9:61Angles of Attack
§9:62Cross-Examination
[§§9:63-9:64 Reserved]
C.Hospital Testing
§9:65Strategy
§9:66Angles of Attack
§9:67Cross-Examination
FORMS
Form 9-AOmnibus DWI Discovery Motion
Form 9-BSubpoena Duces Tecum to Appear and Bring Training Manuals
Table of Cases
Table of Statutes
Index