Direct examination typically consists of open-ended questions that invite the witness to responds with a narrative manner.
2. Manner of Presentation:
While narrative presentations is the standard method by which parties offer direct evidence, narrative is not the only means by which to offer direct evidence:
a. General Rule: A party may not pose leading questions to his or her own witness.
i. A party may use leading questions if the party has called a hostile witness or adverse party to testify as that party’s own witness
ii. A party may use leading questions to assist a witness on direct examination who has difficulty responding due to a mental or physical defect or impairment.
iii. A party may used leading questions on direct examination to establish background facts not in controversy.
Counsel may prepare a witness for trial and rehearse the witness’s testimony provided that preparation does not alter or skew the witness’s testimony.