Steps after completing the index of testimony.

JurisdictionUnited States

Section 44. Steps after completing the index of testimony.—Having completed your index of the testimony, you will have a fairly good idea of the scope and extent of the record in your case and of the major topics it involves. The next step, then, is to block out the order in which you will set forth those topics in the Statement of Facts. Having done that, you are ready to write: your outline is your guide, your topical index gives you the key to the materials, and you can fill in the record references as you go along. You will frequently need to refer to the actual transcript, either to get the exact page reference whenever the index notes refer to several consecutive pages lumped together, or whenever you deem it helpful to quote exactly from a witness or a document. But, given outline and index, you have control of your materials, no matter how bulky they are, and you should therefore be able to make very satisfactory progress.

It is well to pause at this point to stress the absolute necessity for having record references to every portion of the Statement of Facts. That need simply cannot be overemphasized. For one thing, a Statement of Facts buttressed by record references carries a reassuring conviction to the reader. For another, when...

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