I want to ask how to desire questions about impeachment in cross examination as defendent using the materials below, based the issues of character, bias, prejudice, and motive to fabricate. Can you give me a sample?

SUMMARY OF BROOKE THOMPSON'S TESTIMONY AT FIRST TRIAL BROOKE L. THOMPSON, called to testify as a witness for the State and having been duly sworn, testified as follows. My name is Mrs. Brooke L. Thompson. I live at 1751 Madison Street, Nita City, Nita. I am forty-nine years old. I am a widow. My husband, Henry J. Thompson, died on October 1, YR-14. We had no children. I married him in YR-22. It was my first marriage and his second. His first wife died in YR-24. They had one child, Leslie, who was six years old when I married Henry. Leslie was my stepdaughter. My husband had been a prominent lawyer in Nita City, and then, during the first year we were married, he was appointed judge for the Circuit Court here in Nita City. He was a judge until he died. When I married Mr. Thompson, he owned the house at 1751 Madison. I have lived there ever since. Of course, Leslie, my stepdaughter, lived there too until she married Joe Mitchell. In his will, my husband left all his property to me for my life and then to Leslie when I die. The will provided that if Leslie were to die before me, I could dispose of the property as I see fit. The will also set up a trust fund for Leslie and me, with the Nita National Bank and Trust Company as trustee. I was also named Leslie's guardian until she was twenty-one. Her father's estate had given me an income of $75,000 a year on the average, mainly from stocks, bonds, and other investments. Because of poor investment decisions and a faltering economy, my income sank to $40,000 per year in YR-4. I had a life insurance policy on Leslie for $600,000. I was the beneficiary, and the policy had paid off, double indemnity. So I received $1,200,000 on it a couple months after she died. The double indemnity provision included homicides, unless, of course, the beneficiary was the killer. After my income fell so dramatically, I needed to make more money, so in YR-3, on the recommendation of a real estate agent, I bought two apartment buildings in a rather unpleas- ant part of Nita City. All the residents were minorities-about twenty-four families, or what they call families. The real estate guy said I was in a good position to have a steady income because the judges knew I was a judge's widow and would be "attentive to my concerns" in any building court cases. Those cases are a big problem for landlords in those neighborhoods. I had a management company run the buildings, but I insisted on collecting the rents myself. You have to lay down the law to those people. The tenants, I mean. So I went over there on the first of the month and collected the rents myself-no ifs," "ands, or buts." If they didn't have the rent right there in cash or money order, I just phoned in the names and began eviction proceedings. Even if they came up with the money the day after, that was just too bad. It's important to maintain your credibility. I carried my .38, and it was a good thing, too. Once this guy came at me with a knife, and I shot him right in the chest. Justifiable homicide, the police said. They also told me I was crazy to collect the rents in those buildings myself, but it hasn't stopped me. Leslie and I lived comfortably on Madison Street. Although I never formally adopted her as my daughter, I always regarded her as mine. I loved her and took care of her upbringing as Probs. & Mat'ls in Evidence & Trial Advocacy, Vol. I Cases if she were my own child. She was so young-only four-when her own mother died that she could hardly remember her. She called me "mother," and our relations were always the inti- mate relations of mother and daughter. I was interested in her welfare and in her future hap- piness, and I always wanted to advise her as her mother. I supported Leslie, sent her to school, and raised her. For high school, she went to Green- wood Academy, a private boarding school for girls in Jackson City, Nita. She graduated there in YR-10. Then, because she didn't want to go to college, I sent her to the Katherine Gibbs Business School in New York in YR-6. She came back to Nita City and got a job at the First State Bank. At the time of her death, she was private secretary to Mr. Robert Allen, the presi- dent, and netting $4,000 a month. Of course, when she married she was also getting about $1,500 a month from the trust fund under the terms of the trust document. I receive that now. Leslie's trust contained the provision that I would maintain title to the principal until she was married for four continuous years. Thereafter she gained control of the principal to do with as she wished. She lived at home with me before her marriage, and all the trust income came to me to use for our benefit as I saw fit. I charged her only market rates for room and board and for household expenses, and I never asked her to contribute to the maintenance of the house. I knew I could have charged more, but I didn't want to-I loved her as my own child. Late in YR-4, she began to date Joe Mitchell. She brought him home one night and in- troduced him to me. When I asked him what he did for a living, he said he was a "writer" of short stories and TV scripts, especially detective stories and murder mysteries. He told me he hadn't sold or placed any of his writing yet. In fact, he hadn't made a cent out of it. But he said he was working as a part-time attendant at a gas station to support himself. He said he was then living at Mrs. Porter's Boarding House at 800 Fillmore Avenue in Nita City. At this point in the trial, the following questions were asked and the following answers were given: Page 30 8 11 Q: What was your reaction to Joe Mitchell's relationship with Leslie? 12 13 14 A: I didn't like this man, I admit. And as Leslie continued to date him, my dislike of him increased. I never approved of him. I didn't think he would make Leslie happy if she married him. 15 Q: Did you communicate your disapproval to Leslie? 16 17 18 A: I warned her against marrying him; I thought it was my duty to her as her mother. I told her i thought he was lazy and shiftless and would ruin her life. National Institute for Trial Advocacy State v. Mitchell-Thompson's Testimony Summary 19 Q: Did you say anything more to Leslie about Joe? 20 A: I told her she should date other young men and that she would find she could do better than marrying this fellow. And as it has turned out, my judgment about him was right. 21 22 23 Q: Anything else? 24 A: I said he was lazy and was just after what little money she had or could 25 expect. I was convinced that he'd break her heart. I thought it was my 26 duty to warn her, as her own mother would have, that this man would 27 never make her happy. 7 In the winter and spring of YR-3, Mitchell came to our house many times. He dated Leslie three or four times a week. She told me that she had to pay for the gas for the car and for the dinners and shows they went to because "Joe was short of money." I guess she sort of pitied him. In spite of all I did to prevent it, Leslie told me in the summer YR-3 that she was going to marry Joe. I wondered how he expected to support a wife. From what I saw, he was going to live on her money. I told her many times I didn't think Joe was the man for her and that her own father and mother, if they were alive, wouldn't approve of this marriage. I disliked Joe the more I saw of him. From what I saw of him while he was dating Leslie, I thought he was a lazy good-for-nothing. I admit I never had much use for "writers," anyway. I was convinced that he'd break her heart. I thought it was my duty to warn her, as her own mother would have, that this man would never make her happy. But she became defiant and said she was over twenty-one and they would be married, no matter what I or anyone else said. She said she loved Mitchell. This was the first disagreement we ever had. I was heartbroken. I would have done anything to prevent the marriage. If only I had, she would be alive today. But they went ahead and were married by a judge in Nita City on November 15, YR-3. I wasn't present because I was ill. I did not want to do anything to suggest that I was approving of what they had done, so I sent no wedding gift. After their marriage, Joe and Leslie lived in an apartment at 50 Jackson Street. Leslie con- tinued to work at the bank, but Joe quit his job at the gas station so he could stay home and devote all his time to "writing." Leslie supported them both. That's just what I expected would happen. After they were married, they came to my house a couple of times a month, and I was always civil to Mitchell. He admitted he was not making a dime from his writing. They used to come in Mitchell's old white GMC Jimmy. I don't know why Leslie didn't buy a new car. She could drive. She had money. And Mitchell would park the car at the curb right out in front of the house. I had seen it there many times before the night he shot Leslie. Probs. & Mat'ls in Evidence & Trial Advocacy, Vol. 1 Cases Sometime in late July of YR-2, Leslie came home one night in a taxi. She and Mitchell had separated after a bitter argument. She said she had tried to get Joe to give up his writing and take a job at the bank, but he had refused. I told her I was glad to have her back home without Joe and that she certainly could live with me. After they separated, Leslie lived with me, and Mitchell went back to live at Porter's Board- ing House on Fillmore Street. Mitchell would come to the house about twice a week and argue with Leslie to get her to come back to him. She always refused to go back to him unless he quit his writing and got a real job. I was always present during these arguments. I didn't trust him; I was also afraid that with all his smooth talk, he would get her to go back. So I insisted on being present. After all, it was my house, and it was my duty to watch out for her welfare as her mother. I didn't want to see her heart broken any more than it was already. I told her not to go back to him and urged her to consider divorcing him. Several times I told Mitchell in very plain language what I, Leslie's mother, thought of it all. I told him he was lazy and a no-good to be living off his wife's income. We had bitter words in Leslie's presence, and a couple of times he threatened me. He said something about getting even with me because I had broken up his marriage to Leslie. (I am not sure of his exact words, but that's what he meant.) And several times he threatened to hurt me or Leslie for ruining his marriage. This man had a violent temper. Sometimes he would try to coax Leslie to come back to him; other times he would fly into a rage. and One time in late August, YR-2, he was at the house arguing with Leslie and got angry rushed out of the house. He slammed the front door so hard I thought it was smashed. I ran to the door and opened it, and I saw him run down the walk. I saw him get into his car at the curb across the street. I could see him clearly, even though it was about 9:30 p.m. and dark and raining. I watched him get into the car, and then, before he drove away, I saw him lean out of the car window and shake his fist at me. I was standing at the door, and I could easily see him and recognize his face-pale and sort of drawn. As I said, he had an uncontrollable temper. When he came to see Leslie, he would shout and scream and say that she was "heartless" and "selfish," and he'd turn on me and accuse me of breaking up his marriage. A couple of times he swore and cursed at us. Then he'd storm out of house, but a few days later he'd be back, and the same things would happen again. Leslie would never leave the house with him. He would ask her to go with him "to talk things over" where I couldn't be around. She would never do it; she was afraid of him, she said. When she told me that, I told her never to leave the house with him. I was really afraid, then, that he would do something violent to her. The last time he visited her before he killed her was on September 9, YR-2. I was present. He didn't quarrel with her then, and he only stayed a little while between 9:00 and 10:00 p.m. He asked her to come back to him. He said: "Leslie, I'm asking you for the last time. You'd better listen to me now, if you know what's good for you." And she said: "Joe, I'm not coming back until you get a real job and quit this silly stuff about writing." He said: "You know I won't do that. I'm not giving up my work, even for you." She said: "Then this is the 10 National Institute for Trial Advocacy 9 way State v. Mitchell-Thompson's Testimony Summary way you it's got to be. I'm all through with you, Joe. I'm sorry it worked out like this." Then Joe said: "Well, I guess there's no use trying anymore, the feel. I won't bother you again. But don't forget this-I'm going to make you regret what you've done to me, if it's the last thing I ever do." Leslie then said, "Are you threatening me?" And he just looked at her real mean and angry. Then he said to me: "You are an evil person. You turned Leslie against me. You broke up this marriage, and I'll see that you pay for this. You'll be to blame for whatever happens now." I cannot swear to the exact words used that night, but I do remember the substance of what each said. Mitchell left the house at about 9:30 p.m. Just before he left the house, Joe went into the next room to get his jacket. While he was gone, I said to Leslie: "That man's a loser. I'd rather die than see you go back to him." At that moment he came back into the room and glowered at me. I think he heard me, and it made me nervous. my Yes, I did own a Smith and Wesson .38 caliber revolver, which I bought a few years ago. It was registered. I kept it in the drawer of the night table next to my bed in bedroom on the first floor of the house. I last saw it on the first or second day of September when I hap- pened to be looking in the drawer. Joe had seen me put the gun in that drawer several times. I looked in the drawer a couple days after Leslie's death, and it was empty. I didn't say anything to the police about its disappearance because I didn't think it was that important. I mentioned it only when the detective asked me if I owned a .38 and whether they could see it. That was about three weeks after Leslie's death. Frankly, I think Joe took it. The gun they recovered from Joe was not mine. The next day, September 10, was Leslie's birthday. We had dinner at 6:00 p.m., and I gave her a ring for a present. At about 7:00 p.m., she left the house to go to a movie at the Palace Theater. She said she would be home around 10:00 p.m. She went alone. The theater is on Madison Street, about five blocks east, and she walked. It wasn't raining then, but she took an umbrella with her. It was a warm sort of fall evening. After she left, I went upstairs. I noticed that she had left the light on in her room-the front bedroom on the east side of the house. I went in to turn it off, and I noticed she had left her front door key on the night table. I also saw a piece of paper with some handwriting on it, but I didn't read it then. I decided to for her, since she had forgotten her key. wait up At 7:30 p.m., the front doorbell rang. I went to answer and opened the door. It was raining then, but just a drizzle. I saw Mitchell standing on the porch. His car, that old white Jimmy, was parked at the south curb across the street-facing east. He asked for Leslie. I told him she had gone to the Palace Theater. He wanted to know when she'd be home, but I said I wasn't sure. I told him this because I didn't want him bothering her again after what he'd said last night he had said that he wouldn't see her again. I was afraid for her. (I expect that he knew that Leslie almost always went to Heggarty's after seeing a show and almost always stayed until 12:30 a.m. or so. Heggarty's is one of those beer, burger, and ice cream places where neigh- 1 young people gather. Nice quiet place a couple blocks east of the Palace.) He spoke clearly and calmly. He had something under his right arm. It was wrapped in an old newspa- per, and I couldn't tell what it was. He was wearing a sort of black or dark blue jacket. borhood Probs. & Mat'ls in Evidence & Trial Advocacy, Vol. I Cases Around 10:00 p.m., the doorbell rang again. I went and opened the door. (It opens in.) Leslie was there. She was standing on the porch about two or three feet from the step. The bracket lights at the door were on. I also had the lights on in the two front rooms on the first floor, and the window drapes were open. Leslie had her back to the street. It was raining and dark-cloudy and no moonlight; there was no street light at the curb. But there was a street light at the south curb, across the street- thirty feet west of my front door. At this point in the trial, the following questions were asked and the following answers given: Page 42 3 Q: What happened next? 12 4 A: Just then, I heard a car coming from the west and going east on Madison. There were no other cars on the street. I looked out and saw a white SUV 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 21 22 223 -it was a GMC Jimmy, same style and shape as Mitchell's. You see, I had the door open, and I looked out over Leslie's head as she stood down on the porch. The car came on fast, going east. All of a sudden, I heard the brakes squeal, and the car stopped out at the curb right in front of our house. I sud- denly realized this was Mitchell's car, and then Leslie cried out, "Oh no... oh no, Joe!" or something like that. It all happened in a matter of seconds. I saw a man lean out of the car window-put his head and shoulders out of the front window on the side facing us. He didn't have a hat on. I saw a small, dark object in his hand, like a gun or some kind of revolver. Then I heard a shot-only one shot-and I saw Leslie fall over backwards. She sort of spun around and fell on the porch, with her head towards the street and her feet in the direction of the door. The car sped away down the street, going east. I saw the taillights, but I couldn't see the license plate number. The motor or engine of this car was running through the whole thing-I could hear it all the time the car was stopped at the curb. Q: Did you recognize the man who shot your daughter? 23 A: 23 The first thought that flashed in my mind was that Joe had shot my daughter. I can positively swear that the face of the man who leaned out of the car National Institute for Trial Advocacy 11 24 25 26 27 28 29 212 22222 3 1 1 30 31 32 33 34 35 The two State v. Mitchell-Thompson's Testimony Summary was the face of Joe Mitchell and that it was his car. I saw his face. I saw the car. I know it was Joe Mitchell. As I told you, I had seen Mitchell hundreds of times before, right out there at the curb in that car-the white Jimmy. And I had seen him there only three hours before. I'm not identifying a stranger I had seen on the night of the murder for the first time; I had seen Mitchell hundreds of times. I knew him; he was no stranger. And I recog- nized the car, too. Joe Mitchell is definitely the man i saw fire the shot from the car. I saw his face for a couple of seconds, but that was enough. Leslie was not blocking my view; she was only five-foot, two-inches, and was standing down on the porch, while I was on the step at the door, about one foot up from the porch. Leslie had an umbrella and was just closing it, but she had it down when she turned and faced the street. o porch lights were on, and there was light from the two front-room windows. The car had its headlights on. No, there wasn't any moonlight. It was dark and rainingnot hard, but there was rain splashing on the porch. Some neighbors came running over right away and took me into the house. I was in shock. Some police came, but I don't know who called them. One of the police officers-I can't remember his name now-asked me some questions, and I told him pretty much what I've you. I told him Leslie's husband was Joe Mitchell and that he lived at Porter's Boarding House at 800 Fillmore Avenue. I said that Joe Mitchell had shot and killed his wife, Leslie, my stepdaughter. When the ambulance came to take Leslie to the hospital, I rode along, and a doctor there pronounced her dead on arrival. Then I had to identify Leslie's body to a man told who said he was the coroner. I'm sure it was 10:00 p.m. when Leslie came home from the Palace Theater, because just as she rang the doorbell, I heard my clock in the living room strike ten. I only saw Mitchell out there in the car for a few seconds, but saw the car for a longer time. I saw it coming for about four to five seconds before it stopped. Then I saw Mitchell lean out of the window, take aim, and shoot Leslie. September 10 was Leslie's birthday. When Mitchell came to the house earlier that night asking for Leslie, he didn't say anything to me about her birthday. The package he had under his arm was large enough to conceal a pistol or handgun. He didn't have a hat or an umbrella, and his jacket was soaked with rain. Probs. & Mat'ls in Evidence & Trial Advocacy, Vol. I Cases One day while Mitchell and Leslie were dating, he came to the house to see Leslie, and he had a handgun with him. He said he had been out target shooting with the gun. He claimed he was an expert shot. After Leslie's funeral, I was in her room, and I remembered the piece of paper I had seen on her night table the night she was shot. I looked at it then, and it was a letter to Leslie from Joe. I recognized the handwriting-it is Joe Mitchell's handwriting. I had seen him sign our guest book once, and I've seen his handwriting on his letters to Leslie. The handwriting on the letter is the same as the handwriting on the guest book and the letters. I remember that on the morning of September 10, a letter came by overnight delivery for Leslie. I recognized Mitchell's handwriting on the envelope. No, I have never found this en- velope. I gave Leslie the letter when she came home. That night at dinner, she said the letter was from him. She never said what was in it, and we never discussed this. At this point in the trial, the following questions were asked and the following answers given: Page 50 8 9 10 11 12 13 14 Q: Do you know of anyone else who might have had reason to hurt you or Leslie? A: Well, there's one other thing maybe I should mention, although I'm sure there's no connection. My husband, Leslie's father, had been a judge for several years before his death. He handled some notorious criminal trials, and I'm sure along the way he made some enemies, particularly some of those he sentenced. 14 Q: Do you know of any specific dangers? 15 A: I remember one case especially, because I read in the newspaper last August 16 17 18 19 20 21 222 223 2 24 that the person my husband had sentenced had been paroled and was returning to Nita City. That case involved a fairly well-known businessman who was convicted of killing his business associate. There was a lot of pub- licity and talk of connections with gambling and organized crime. My husband was under a lot of pressure at the trial and sentencing. He said he had to do his duty and do what the law required. The jury found the man-I think his name is John Bierman-guilty, and my husband sentenced him to something like twenty-five to thirty years in prison. This was all about fifteen years ago, just a couple of years before my husband died. National Institute for Trial Advocacy 13 25 26 27 28 29 State v. Mitchell-Thompson's Testimony Summary Q: Was there any specific reason to believe that this Bierman might seek revenge? A: At the sentencing, Bierman said he was innocent and had been framed by my husband and the prosecutor. My husband said in his remarks from the bench that he had talked the sentence over with "my wife" and was sure it was fair. I wish he had not said that. Bierman said he'd get revenge "on you and your 30 goddamn wife" for having his life ruined and losing his family in a frame-up if 31 it was the last thing he did. 32 33 34 35 Q: But you didn't take this threat seriously did you? A: My husband and I were concerned about this threat at the time, and I remember him talking about it for some time. I also remember that Bierman had a wife and three children and that she divorced him and left town shortly 36 after he went to prison. Naturally, he lost his business when he went to prison. CERTIFICATION BY COURT REPORTER The above is a true and accurate transcription of (Mrs.) Brooke Thompson's testimony at the trial of the case of State v. Mitchell, which testimony was recorded stenographically by me at the time it was given. Signed and Attested to by: A Marie Lane Certified Court Reporter Probs. & Mat'ls in Evidence & Trial Advocacy, Vol. I 15