Miller Cross

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    Cross examination of Max Miller

    Lawyer:Mr. Miller, The Joint serves alcohol, does it not?

    Miller:Yes.

    Lawyer:And you have underage patrons at The Joint too, is that right?

    Miller:Yes.

    Lawyer:But certainly these underage patrons dont drink... do they?

    Miller:Well, I dont sell it to them, but...

    Lawyer:Do you have underage patrons who drink, yes or no?

    Miller:Yes, I do.

    Lawyer:And has this caused any problems for you?

    Miller:Well, Ive had some trouble with the SLA...

    Lawyer: So, Mr. Miller, has The Joint ever had any other incidents besides the underage drinking and

    the beating?

    Miller:Yes. Someone was stabbed in The Joint in September of 2010. (If they try to explain further, cut

    them off.)

    Lawyer:And this caused problems for you and your business, didnt it?

    Miller:Yes. The SLA (State Liquor Association) investigated.

    Lawyer:And, after this incident, the SLA told you that any further criminal activity could result in a

    revocation in your liquor license, am I correct?

    Miller:Yes.

    Lawyer:Mr. Miller, what would happen if the SLA took away your liquor license?

    Miller: (may ramble here; try to keep that from happening by repeating the question)... I would have to

    close down The Joint. I wouldnt make enough money.

    Lawyer:So, youre saying youd want to make sure there wasnt any more criminal activity at The Joint,

    correct?

    Miller:Yes.

    Lawyer:And clearly, a conviction on this beating that occurred outside of your establishment would

    count as criminal activity, yes?

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    Miller:Yes.

    Lawyer:Youre telling me that if there was a conviction on Ms. Malones attacker, you could lose your

    liquor license and your business?

    Miller:Yes.

    Lawyer:Moving on... Mr. Miller, what is your opinion on the defendant and her best friend?

    Miller:(may try to skirt around the issue, talk about valued customers, etc...)

    Lawyer:Mr. Miller, do you like Ms. Malone and Mr. Tecrest?

    Miller:Yes/No.

    NOTE: If he tries to deny it, ask him if he ever called Tecrest slimy; if he ever said I wouldnt put it past

    Dana and Ryan to have made up all of this stuff, that It wouldnt bother me one bit if Ryan and Dana

    never came to The Joint again. If he continues to deny it, admit the affidavit into evidence, make himread aloud highlighted passages, re-ask the question.

    Lawyer:Again, Mr. Miller... do you like Ms. Malone and Mr. Tecrest? Do you think highly of them?

    Miller:No, I dont.

    Lawyer:Any finally, Mr. Miller, do you actually think an assault occurred in your parking lot on March

    18th, 2011?

    Miller:No, I dont.

    NOTE: If he denies it, bring the affidavit back into evidence again. He says it right in the final paragraph:

    I really dont believe anyone was attacked in myparking lot on March 18, 2011.

    Lawyer:No more questions, your honor.

    I wouldnt put it past Dana and Ryan to have made up all of this stuff.