Trial Testimony - Questions for Impeaching Witness on Cross - Examination by Showing Hostility
(By Counsel)
Q. How do you feel about the defendant stopping payment on the check she gave you?
Q. Are you angry at her?
Q. Are you very angry at her?
Q. Weren’t you so angry at her that you threatened her, saying that if she didn't pay you, you would report all of this to Mr. _______?
Q. Didn’t you follow up on your threat and report all this to Mr. ____?
Q. Wouldn’t you would do or say anything to get back at her?
Q. Isn’t your testimony here today actuated by feelings of hostility and revenge?[1]
[1] People v Thomas, 46 NY2d100
(By Counsel)
Q. How do you feel about the defendant stopping payment on the check she gave you?
Q. Are you angry at her?
Q. Are you very angry at her?
Q. Weren’t you so angry at her that you threatened her, saying that if she didn't pay you, you would report all of this to Mr. _______?
Q. Didn’t you follow up on your threat and report all this to Mr. ____?
Q. Wouldn’t you would do or say anything to get back at her?
Q. Isn’t your testimony here today actuated by feelings of hostility and revenge?[1]
[1] People v Thomas, 46 NY2d100
The material on our website is from the New York Matrimonial Trial Handbook , by Joel R. Brandes of the New York Bar. It focuses on the procedural and substantive law, as well as the law of evidence, that an attorney must have at his or her fingertips when trying a New York matrimonial action or custody case. It is intended to be an aide for preparing for a trial and as a reference for the procedure in offering and objecting to evidence during a trial. There are numerous questions for the examination and cross-examination of witnesses.
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The New York Matrimonial Trial Handbook is available in Kindle ebook editions and epub ebook editions for all ebook readers in our website bookstore and in hard cover at our Bookbaby Bookstore.
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This website is published by Joel R. Brandes Consulting Services, Inc., and written by Joel R. Brandes of The Law Firm of Joel R. Brandes. P.C. Mr. Brandes has been recognized by the Appellate Division* as a "noted authority and expert on New York family law and divorce.” He is the author of the treatise Law and The Family New York, 2d (9 volumes),Law and the Family New York Forms 2d (5 Volumes), Law and the Family New York Forms 2019 Edition (5 volumes)(Thomson Reuters), and the New York Matrimonial Trial Handbook. Click here to visit New York Divorce and Family Law ™ the definitive site on the web for New York divorce and family law, presented by Joel R. Brandes of the Law Firm of Joel R. Brandes, P.C., 43 West 43rd Street, New York, New York 10036. (212) 859-5079.
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