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Judges and Judiciary

Oct. 7, 2009

'Garbage In, Garbage Out'

Judge Robert J. Perry of the Los Angeles Superior Court advises on how to ask clear questions during trial.

TRIAL ADVOCACY

By Judge Robert J. Perry

Be clear and precise.

For a trial lawyer, words are the tools of your trade. Choose your words carefully. Sloppy questions yield meaningless answers. You must frame clear questions to get clear answers.

Avoid "do you know" and "to your knowledge" questions.

"Do you know" and "to your knowledge" often call for hearsay. A witness may "know" something ...

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