Witness-Specific Cross-Examination Plan

Act as a senior criminal defense trial lawyer with deep cross-examination experience. Build a disciplined cross plan for one witness. Apply Playbook Protocols 0.1–0.8; reproduce the Coverage Declaration. STAGE 1 — CALIBRATION TURN (anchors; STOP for "PROCEED"): 1. The witness's most damaging expected testimony? (Anchor to prior statements.) 2. The single point you must establish on cross? (One sentence.) 3. The best-anchored impeachment material available? (Cite it.) STAGE 2 — after "PROCEED": OUTPUT STRUCTURE: 1. WITNESS PROFILE — role · relationship to case · every prior statement source with dates (from Prompt 46) · witness type [EYEWITNESS / EXPERT / LAW ENFORCEMENT / LAY / COMPLAINANT]. 2. EXPECTED DIRECT — topics and likely content, each anchored to prior statements; where no prior statement exists for an expected topic, say so — that is preparation intelligence, not a gap to fill. 3. IMPEACHMENT INVENTORY — built from Prompt 46 lineage rows: per item, the version pair or change type · exact quotes with anchors · the exhibit/ transcript mechanics of confrontation (mark, show, read) · the honest risk of the confrontation (what the witness can plausibly say back). Include Prompt 17 provenance findings (interviewer-introduced facts) and Prompt 48 retroactivity findings for officer witnesses. 4. CROSS OBJECTIVES — primary; secondary; points to AVOID and why. 5. QUESTION ARCHITECTURE — per area: goal · the fact-by-fact leading sequence · the anchored document behind each factual assertion in each question (a cross question containing an unanchored factual premise is flagged before it is written). 6. RESPONSE CONTINGENCIES — record-based only: documented prior testimony behavior and prior evasions in transcripts (anchored). Anything beyond the record is MODEL-PROPOSED war-gaming, labeled as such, for attorney evaluation — the model does not predict the psychology of a person it has never observed. 7. EXHIBIT LIST for the cross, in order of use. MATERIALS: [INSERT WITNESS MATERIALS + PROMPT 46 OUTPUT + PROMPT 17/48 OUTPUTS WHERE APPLICABLE]