Direct examination of Allen Cowlings by Daniel Petrocelli (2 of 3)

📄 Direct examination of Allen Cowlings by Daniel Petrocelli (2 of 3) — Wednesday, May 15, 1996

Address:

C:\DEPT103\DEPOSITION\1996\MAY\15\DIRECT-EXAMINATION-OF-ALLEN-CO.DOC

TRIAL

▲ Day 29 of 31

◀ Direct examination of Allen Cowlings by Michael Brewer Direct examination of Allen Cowlings by Michael Brewer ▶

Witness: Allen Cowlings
Examiner: Daniel Petrocelli
Called by: Plaintiff • Date: Wednesday, May 15, 1996 • Lines: 6

During direct examination, Daniel Petrocelli asked Allen Cowlings to distinguish between possibly having made a statement to Cora Fischman during a walk and specifically remembering making it. Cowlings said he did not remember, after which Dan Leonard objected that the question was vague and compound.

# 1

BY MR. PETROCELLI:

# 2 Q:

Okay.

# 3 A:

but I could have said it.

KEY QUOTE

# 4 Q:

When you say that you could have said it, let's see if we can differentiate that answer. Do you have a specific memory as you sit here today of making that statement or a similar statement to Cora Fischman during the course of this walk?

# 5 A:

I don't remember.

# 6 MR. LEONARD:

Objection. Vague, compound.

Temperature

procedural

Key Quotes (2)

Allen Cowlings

I don't remember.

Cowlings states that he does not remember making the statement described in Petrocelli's question.

Allen Cowlings

but I could have said it.

Cowlings allows that he may have made the statement without claiming a specific memory; Petrocelli's next question seeks to clarify that distinction.

Notable Exchanges (1)

Daniel Petrocelli•Allen Cowlings

Petrocelli asks whether Cowlings specifically remembers making the statement or only allows that he could have made it; Cowlings says he does not remember.

clarifying

Credibility Attacks (1)

⚔ Allen Cowlings

memory clarification

Petrocelli asks Cowlings to distinguish between the possibility that he made the statement and a specific present memory of making it.

Objections

1 objections (0 sustained, 0 overruled)

Proceeding 9003 • 6 lines • Plaintiff witness

Deposition Trial

Department 103