[blindlaw] Refreshing and impeaching witnesses with depositions andother documents: tips needed please!

[Locke Milholland]

My advice,
Out of the deposition you have, you know what you are going to ask.  When 
cross examining, you know what parts are going to need be impeached.  These 
will be the only precise notes you'll need.  Braille out those and include 
the page number and line number, or have someone highlight them on the 
cross-example to ask the witness to read the highlighted text.

They'll know what they are looking for when using it to refresh their 
memory, so notes won't be required on this part.

Locke



----- Original Message ----- 
From: "Rod Alcidonis" <roddj12 at hotmail.com>
To: "NFBnet Blind Law Mailing List" <blindlaw at nfbnet.org>
Sent: Monday, January 14, 2008 4:41 AM
Subject: [blindlaw] Refreshing and impeaching witnesses with depositions 
andother documents: tips needed please!


Hello everyone:

Please advise...

I am about to begin practicing with the trial team here for the Texas Young 
Lawyers Association competition next month. I have to direct one witness and 
cross-examine a police officer. It is expected that these witnesses will 
forget the facts in the package and thus will need to have their 
recollections refreshed at trial with their depositions, and of course, the 
officer in particular will have to be impeached.

I am a Braille reader and I use a Brailliant Braille display with my laptop. 
I also have the option of brailling out my notes or the witnesses 
depositions on paper if needed. I also have the option of using an 
assistance if I wanted to but this would have to be only if that's the most 
effective way because that person would have to be one of my teammates.

How do you guys go about navigating these documents while examining a 
witness, and be able to point directly to the page and line numbers when 
referring witnesses to documents and not waste too much time?

I don't know if I should just Braille the depositions even though the pages 
won't match up with the printed document, or just use my laptop to find the 
text and refer the witness to it instead. I would certainly appreciate some 
constructive feedbacks please.

Thanks.


Rod Alcidonis
Juris Doctor Candidate, 2009.
Roger Williams University School of Law
10 Metacom Ave., Box: 9003
Bristol, RI 02809
Cell: 718-704-4651
Home: 401-824-8685
Visit my Law School Blog at:
http://blogs.rwu.edu/law/ralcidonis




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