Five Tips for Preparing an Organized Trial Cross-Examination Outline

This article was originally published in the American Bar Association's Mass Torts Litigation newsletter (December 2024). 

The key to an effective cross-examination is preparation. The evidence of good preparation is an organized trial cross-examination outline. By the time the trial lawyer gets on their feet to cross-examine the witness, the outline should be finely honed. Though an experienced trial lawyer will not use the outline as a script, it will be the tool they use to advance the client’s narrative and impeach the witness’s credibility. A well organized outline is even more important when the witness is a seasoned expert. The following tips are focused on preparing an organized trial cross-examination outline for experts, but these tips can be applied to any outline. Before following these tips, be sure to communicate with the trial lawyer on any personal preferences.