Cross-examination is about establishing a small number of points through questions the witness cannot avoid.

Leading questions only. Statements with a question mark. Any question beginning with why, how or explain surrenders control.

One fact per question. Compound questions invite qualification and give the witness room.

Short questions, plain words. Long questions with embedded qualifications are where witnesses escape.

Know the answer. Every question should be supported by a document, a transcript page or an undeniable proposition.

Build to the point without announcing it. Establish the premises, then stop. Asking the ultimate question invites the explanation that undoes the sequence.

Impeach cleanly. Commit to the trial testimony, accredit the prior statement, then read it. Three steps, in order.

Do not fight. A witness who is arguing is being helped. Move on and return later.

Choose three points. A cross that establishes three things the jury will remember is more effective than one covering everything the witness said.

Sit down. Continuing after the points are made allows the witness to repair the damage, and juries notice when counsel does not know when to stop.