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Openings
60‑second opening
“Your Honor, this is a request for [relief] because [key facts]. I will be brief. The evidence will show [1–2 anchors]. I’m asking the Court to [specific order].”
Framing issues
“The issues today are narrow: [Issue 1] and [Issue 2]. I’ll address each with exhibits and brief testimony.”
Introducing Exhibits
Document foundation
“Your Honor, I offer Exhibit A, a [document] dated [date]. I obtained it from [source]. It is a fair and accurate copy.”
Photo / video
“This photograph/video fairly and accurately depicts [scene] as of [date/time]. I took it / It was provided by [name].”
Business record (basic)
“This is a business record kept in the ordinary course by [entity]. It was made at or near the time by someone with knowledge.”
Objections
Evidence / Questions
- “Objection, hearsay.”
- “Objection, relevance.”
- “Objection, foundation not laid.”
- “Objection, asked and answered.”
- “Objection, beyond the scope.”
- “Objection, speculation.”
Procedure
- “Objection to form.”
- “Objection, assumes facts not in evidence.”
- “Move to strike as non‑responsive.”
- “Request a limiting instruction.”
Preserving the record
“For the record, I object on [rule/ground]. If overruled, I respectfully proffer that my testimony/exhibit would show [brief offer of proof].”
Witness Questions
Direct (your witness)
- “Please state your name and relation to this case.”
- “On [date], what did you personally observe?”
- “I’m showing you Exhibit A; do you recognize it? What is it? How do you recognize it?”
- “Is Exhibit A a fair and accurate copy?”
Cross (their witness)
- “Your testimony today relies on what someone else told you, correct?”
- “You didn’t see [event] yourself?”
- “There’s nothing in your notes about [fact], is there?”
- “Yes or no: the policy requires [requirement], right?”
Impeachment with a prior statement
“On [date], you wrote [quote] in [record], correct? That is different from what you just told the Court, isn’t it?”
Closings
Simple close
“For these reasons—[fact 1], [fact 2], and [law/rule]—I ask the Court to grant [relief].”
Findings & order language
“Your Honor, if the Court is inclined to grant the request, I ask that the order include: [specific findings] and [clear directives and dates].”
More tools
Continuance (good cause)
“Your Honor, I request a brief continuance for good cause: [reason]. I have