MMT: Procedures (2025-2026)

Trial Proceedings

Courtroom Set-Up

  • Plaintiff sits closest to the jury box; Defense sits farthest from jury box.

  • Bailiff sits in jury box, court reporter’s seat, or another designated seat equally visible to both parties.

Opening of the Court & Swearing of Witnesses

  1. Bailiff of the Plaintiff calls the court to order:

    • “All rise. The Court will now hear the case of Micah Ballan versus Chesapeake Corrections, Inc. and Dylan Oberfeld. The Honorable _____________ presiding.”

  1. Judge permits court to be seated and asks if each side is prepared

  2. Judge asks attorneys for preliminary matters

    • Attorneys may introduce themselves and ask for court preference; they may not raise substantive legal issues.

  3. Bailiff of the Defense administers the Oath while the witnesses raise a hand: [Rule 603]

    • “Do you affirm to tell the truth, the whole truth, and nothing but the truth under the pains and penalties of perjury?”

Opening Statement

  • Plaintiff: 

    • Introductions

    • Summary of supporting facts

    • Summary of evidence to prove

    • Avoid arguments

  • Defense:

    • Introductions

    • Summary of weakening facts

    • Summary of evidence to deny

    • Avoid arguments

    • Avoid repeating undisputed facts

    • Avoid mentioning strong points for Plaintiff

Direct Examination

  • Goals:

    • Introduce undisputed facts

    • Enhance the likelihood of disputed facts

    • Lay the foundation for exhibits

    • Reflect on witness credibility

  • Refer to Rule 611

Cross Examination

  • Goals:

    • Cast doubt on the opposing witness’s testimony

    • Show inconsistencies and bias

    • Establish damaging facts

  • Refer to Rule 611

Redirect Examination

  • Goals:

    • Clarify testimony cast in doubt

    • Avoid repeating testimony

  • Refer to Rule 611

Recross Examination

  • Goals:

    • Respond to matters that arose during the redirect

    • Avoid repeating testimony

  • Refer to Rule 611

Voir Dire

  • Goals:

    • Determine if an expert witness is competent

  • Refer to Rule 702

Steps to Admit Evidence

  1. Show opposing counsel the potential exhibit

  2. Request the judge’s permission to have the exhibit marked for identification:

    • “Your Honor, at this time I would ask to approach the bench for the purpose of having an exhibit, which I have shown to opposing counsel, marked for identification.”

      • This step is unnecessary if the judge agrees to premarking all potential exhibits during preliminary matters.

  1. Request the judge’s permission to approach the witness.

  2. Show the potential exhibit to the witness

  3. Lay foundation:

    • “I am handing you what has been marked for identification as Exhibit X. Do you recognize this?”

    • “What is it?”

    • “Is it a fair and accurate copy?”

  4. Request the court to admit the potential exhibit into evidence:

    • “Your Honor, the Plaintiff/Prosecution/Defense moves what has been marked for identification as Exhibit X into evidence.

  1. If it is admitted, the exhibit should remain with the judge (or court clerk) after the witness’s examination ends.

Steps to Impeach Witnesses

  1. Have the witness repeat the incorrect statement:

    • “Is it your testimony that [insert exact quote of oral testimony if possible]”

      • If the witness agrees, proceed.

      • If the witness recants the inconsistent statement, there is no need to impeach.

  1. Retrieve the sworn statement/affidavit/deposition of the witness

  2. Follow steps 1-4 above (opposing counsel → identification → approach → show)

  3. Ask the witness (using the example of a deposition transcript),

    • “I am showing you what has been marked for identification as Exhibit [X]. This is a transcript of your ____, isn’t it?”

    • “And this is your signature, isn’t it?”

    • “And when you signed this transcript you agreed that the statements made in this _____ were the truth, didn’t you?”

    • “Let me direct you to page [x] line [y] of that transcript. There you testified [read the exact words from the _____ ].”

    • “I read that correctly, didn’t I?”

Closing Arguments

  • Plaintiff:

    • Review legal elements to prove

    • Describe evidence sufficiency

    • Explain how the Defense’s evidence is not credible or convincing

    • Can present a rebuttal argument

  • Defense: