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Guide Cross Examination

The document contains questions for cross-examining a witness named Dianne Lee regarding her testimony about surprising her friends Peter and Alicia on Alicia's birthday. Many questions are aimed at impeaching the witness by pointing out potential bias in her friendship with Peter or inconsistencies in her account of events on the night in question, such as why the lights were off or not recording the supposed surprise with her video camera.

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Bianca Taylan Pastor
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67 views2 pages

Guide Cross Examination

The document contains questions for cross-examining a witness named Dianne Lee regarding her testimony about surprising her friends Peter and Alicia on Alicia's birthday. Many questions are aimed at impeaching the witness by pointing out potential bias in her friendship with Peter or inconsistencies in her account of events on the night in question, such as why the lights were off or not recording the supposed surprise with her video camera.

Uploaded by

Bianca Taylan Pastor
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as DOCX, PDF, TXT or read online on Scribd
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GUIDE QUESTIONS for CROSS EXAMINATION

Witness: Dianne Lee

On Her Friendship with the Couple

1. For the record Madame Witness, do you confirm that all the contents of your affidavit are true?

2. Now Madame Witness, you stated that you are close friends with the private complainant Peter and the accused
Alicia, am I correct?

3. How long have you been friends with them? (Jaime’s Answer – since college/8-10 years)

4. But who are you closer with, PETER or ALICIA?


a. If PETER
i. So you mean to say, you have a closer relationship with your MALE friend than your FEMALE friend?
ii. So you value your friendship with PETER more than your friendship with ALICIA?
iii. Such that if you the group will have a misunderstanding, you will always choose PETER over ALICIA?
(Question is answerable by YES or NO.)
iv. If NO – No? But you stated that you value PETER more than ALICIA, am I correct?

(Note: Try to impeach on account of BIAS.)

b. If ALICIA
i. And as close friend of Alicia, do you often talk to her?
ii. How often?
iii. When was the last time you talked to her?
iv. Have you met her parents? What are their names?
v. How about her family? How many siblings are they?

c. If BOTH
i. How often do you talk to them?
ii. How often do you guys get together?
iii. Do you go to their house? How many times?
iv. And of course as close friends, you would share with each other your problems, am I correct?
v. Did they ever mention to you any of their marital problems?
vi. Did Peter ever confer with you about her suspicions about his Alicia?

5. You stated earlier that your friendship remained strong up until they were married?
a. When was their marriage again? Did you attend the wedding? Where was it held? Where did you go after
the wedding?

6. And even after marriage, you were still friends with them, correct?

7. Such that Peter even asked for your help in surprising Alicia on her birthday, am I correct?
a. When did he ask for your help?
i. If Matagal Na – So you had been planning it for a very long time already?

8. And what was Peter’s plan for the surprise birthday party of Alicia?
i. So it was only Peter, You and Jaime that planned this?
ii. You did not bother to invite her mother or her other relatives?
iii. By the way, how old was Alicia?
On the Night in Question

9. Madame Witness, you claimed that on March 1, 2017 , you, together with Peter and Jaime went to the couple’s
house to surprise Alicia, is that correct?
a. What time did you go?
b. So you just met with each other at Peter’s house?
c. What about Alicia? Where was she at that time?

10. Other than that night Madame Witness, have you previously been to Peter’s house?
a. Can you describe the house of Peter? Who are the members of the household?

11. Madame Witness, you claimed that you entered the house using the front door, is that correct?
a. So the front door was already open at that time? (Expound if NO)

12. You also claimed that the living room lights were off, am I correct?
a. And you did not speculate why the lights were off at that time?
b. But you claimed that Alicia was home, so you did not wonder why the living room lights were off?

13. After that, you proceeded to the master’s bedroom?


a. Where is the master’s bedroom located?
b. In relation to the frontdoor/stairs, where is the master’s bedroom located?

14. When you were already at the door of the master’s bedroom, what happened next?
(Note: Jaime said it was “DIANNE” who opened the door./Affidavit – Peter)

15. And when ____ opened the door, what happened?


a. Can you describe the room? Where was the bed? Was there any light?
b. Where were you positioned at that time madame witness? In relation to you companions/bed

16. So you saw the accused having sex? What was their position? Which side of the bed was Alicia in? What about Will?
17. What was the reaction of Alicia and Will? Where did they go? So they were naked?

Re: Videocamera

18. Madame witness, you stated that you were holding a video camera, is that correct?
19. But there is no recording of such event, am I correct?
20. What was purpose of the video camera then? Ans: To record the surprise event.
21. So basically, you wanted to record how Peter surprised Alicia and to capture the reaction of Alicia, am I right?
22. So from the moment you arrived at Peter’s house, you were already holding the video camera, am I correct?
23. And when you proceeded to the master’s bedroom, you were already recording the surprise, am I correct?
24. Because that was your goal, am I right? To record HOW Peter surprised Alicia and to record Alicia’s reaction?
25. But despite such goal, there was no such recording submitted in court?
26. Because the incident never really happened, am I correct?

(Note: try to move for the production of the recording.)

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