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Direct Exam of _________________________

Fact to get into evidence


• What do we need this witness to say? Is
exhibit needed?
Relevance
• Why is this evidence relevant to your
case?
Hearsay
• Could this evidence raise a hearsay
objection?
• If so, what will the objection be?
Exception/Not Hearsay
• Why is this evidence not hearsay or is
there an exception that applies?
Foundation
• What is the foundation (if any) that
you need to lay before asking the
witness about this?
What is the best way to ask this
question?

Fact to get into evidence


• What do we need this witness to say? Is
exhibit needed?
Relevance
• Why is this evidence relevant to your
case?
Hearsay
• Could this evidence raise a hearsay
objection?
• If so, what will the objection be?
Exception/Not Hearsay
• Why is this evidence not hearsay or is
there an exception that applies?
Foundation
• What is the foundation (if any) that
you need to lay before asking the
witness about this?
What is the best way to ask this
question?

BDDB01 5932852v1

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