http://www.royblack.com/blog/wp-content/uploads/2011/03/Cross-Exam-Checklist.pdf
Cross-Examination Checklist
General Areas of Investigation and Document Retrieval
1. Summary of Expected Testimony
1.1 Testimony Which Can Be Disproved
1.2 Inconsistencies/absurdities
1.3 Contradiction with Other Witnesses
1.4 Helpful Testimony
2. Personal History
2.1 DOB
2.2 Occupation
2.3 Education
2.4 Employment History
2.5 Finances
Assets
Tax Returns
Loan Applications
Employment Applications
Business Applications
Personal Corporation Documents
Legitimate Income
Money
2.6 Family
2.7 Citizenship
2.8 Forfeiture
3. Criminal History
3.1 Convictions
3.2 Other Crimes
3.3 Facts Behind Convictions
Docket Sheet
Indictment
Detention Orders
Bail Reconsideration Motions
Discovery
Suppression Pleadings
Bond Papers
Motions Filed in Witnesses Case
Witnesses Sentencing Memorandum
Names of Criminal Associates
Source of Legal Fees
Probation/Parole
Aliases
Nick Names or Street Names
4. Impeachment – Government Benefits
4.1 Plea Agreement Benefits
Witness Protection
Extent of Cooperation
Pre-sentence Report
Request for BOP Drug Program
Forfeiture
4.2 Sentence Reductions
4.3 Payments
4.4 Prison Facilities
4.5 Parole Consideration
4.6 Immigration Help
Promise for Visa, Green Card
Promise Not to Deport
Help with Family Immigration Status
4.7 Promise of Non-prosecution
Criminal Cases
State Prosecutions
Forfeitures
Tax Liability
Family Members
4.8 Failure to Prosecute on New Crime after Plea
4.9 Expectation of Future Benefits
4.10 Rule 35 Motion
4.11 5k1 Motion
5. Case-Specific Impeachment
5.1 Bias
Relationship to Defendant
Relationship to Others
5.2 Ability to Observe
6. General Impeachment
6.1 Drug Use
6.2 Mental Infirmity
6.3 Acts Proving Poor Veracity
6.4 Acts Proving Bad Character
7. Witness Conspiracy Theory
7.1 Dates and Places of Incarceration with Witnesses
7.2 Contact with Other Witnesses
8. Adverse Character Witnesses
9. Prior Inconsistent Statements
10. Additional Documentation
Tax Returns
Pretrial Detention Pleadings
Objections to PSI
Rule 35 Motions
Rule 35 Transcripts
Order Reducing Sentence
Criminal Complaint
Plea Agreement
News Paper Articles
Grand Jury Testimony
Government Discovery Letters
Motions to Suppress
404b Notice
Firearms Research
Financial Statements
Detention Order
Transcripts
Transcripts of Testimony in Other Cases
Bail/Pretrial Detention Hearing Transcript
Sentencing Transcript
Guilty Plea Transcript
Sentencing Transcript in Prior Cases
General Areas of Cross-Examination
Motivation
Criminal Indictments
Convictions
Sentence
Revocations
Modifications
Forfeiture
Covering for Associates
Covering for Family
Revenge
The Defendant
The Defendant’s Family
The System
The Informant’s Family
Financial
Expenses
Rewards
Tax Cases
Drug
Fees
Living Expenses
Moving Expenses
Usual Incentives
No Prosecution
Immunity
Witness Protection
Dismissal
Plea/Sentencing
Expenses/Reward
Areas of Cross
The Oath
Prior Perjury
Tax Returns
Driver License Applications
Immigration Applications
Guilty Pleas
Bail Hearings
Perception
Competency
Alcohol
Drug History
Mental History
Medical Treatments
Memory
Detail Confusion
Prior Inconsistent Statements
Prior Inconsistent Statements
Agents Reports
Grand Jury Transcript
Motion Hearings
Guilty Pleas
Bail Hearings
Preliminary Hearings
His Motions/Letters
His Pre-sentence Report
His Sentencing Letters
Criminal History
Convictions
Assets
Plea Agreements
This Case
Other Cases
Tax Liabilities
Passes Given on Crimes Committed after Plea Bargain
Expectation of Future Benefits
Other Bad Acts Bearing on Truthfulness
Bias, Interest, Motive and Corruption
Promises
Money
Sentence
Forfeitures
Co-defendants
Bad Character for Truthfulness
Character Witnesses
Other Acts Reflecting on Veracity
Acts Reflecting on Character
Specific Contradictions
Other Witnesses
Other Evidence
Other Informants
Background of Informant
Violations of Prison Rules
Violations of Probation
Community Agreements
Rap Sheet
Immunity Letters
Detention Orders
Home
Community
Friends
Dates and Places of Incarceration
Handling of Informant by Agents
DEA Special Agents Manual
Other Agency or Police Dept Regulations
Cover up Other Crimes by CI
Use of per Diem to Compensate CI
Particular Case Facts
Dishonesty
False Statements
