Irving Younger’s Ten Commandments
1. Be brief.
questions, plain words.
ask leading questions.
4. Don't ask
a question, the answer to which you do not know in advance.
5. Listen to
the witness' answers.
quarrel with the witness.
allow the witness to repeat his direct testimony.
permit the witness to explain his answers.
9. Don't ask
the "one question too many."
ultimate point of your cross for summation.
Irving Younger said that the real number one rule of
Cross-Examination is: “Don’t.”
You are not obliged to cross-examine every witness. Only the novice
cross-examines every time. How do you know when to cross-examine and when
not to? And when you must cross-examine, how do you prepare for it? For
answers to these and other of your deepest questions, read
Controlling the Witness on Cross,