Cross examination Preparation Facts: - You are Mary Colson and you saw the Plaintiff turn right

on a red light and get rear ended by the Defendant - Youve testified that the accident was unavoidable because the Plaintiff ran the red light There are two major inconsistencies in your testimony. In a statement to police in July of 2004 you testified: - You werent really paying attention - You didnt know how fast the cars were going - You didnt know who had the green light Today youve testified that: The Defendants car had the green light The defendants car was going about 20 miles per hour

On September 20, 2004, you were interviewed by an investigator for the insurance company. During the meeting you realized that the light must have been green. (See Q/A below for details of why you know the light was green.) Youll be crossed on: o Why your testimony is different now from your statement regarding the speed of the cars and whether or not the light was green. o Answer yes and no. Dont try to explain. Well take care of it on redirect.

Rehabilitation Questions Q: Mrs. Colson, how are you so sure the light was green that day? A: I had just started into the intersection myself, and I only cross with the green light. 17th and pine is very dangerous. Q: How familiar are you with the intersection? A: I cross it twice daily and I always cross only with the light. In fact, my neighborhood association has lobbied the city council to not allow right turns on red to make the intersection safe for pedestrian traffic. If it the light was green for me, it must have been green for the Chevrolet. Problem 5 Direct of Mark Warden

Would you state your name and place of residence for the court? Do you have prior acquaintance with the defendant, Alan Benjamin? Do you recognize these rings? How do you know these are the same rings?

I would like to call Detective Sam Fletcher. Detective, do you recognize these rings? How do you know they are the same rings found at Als pawn shop?

May I call Mr. Warden back to do the stand? Now that we have established that these are in fact the rings you sold to the defendant, would you please tell the court if the defendant asked any question prior to agreeing to their purchase? (hearsay obj.) In your deposition you mentioned that you sold to the defedent