---
title: "Prepare a cross-examination plan from the disclosed statements"
url: "https://ailawframework.com/practice/criminal-law/prepare-a-cross-examination-plan-from-the-witness-statement/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A20-T1-R8-US"
practice_area: "Criminal Law"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Prepare a cross-examination plan from the disclosed statements

> From the statements the lawyer marks, list the topics, the prior statement that bears on each topic, and the page. Write no question that will be asked in court as if it were the examination script to be read out.

Canonical page: https://ailawframework.com/practice/criminal-law/prepare-a-cross-examination-plan-from-the-witness-statement/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Criminal Law](https://ailawframework.com/practice/criminal-law.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | From the statements the lawyer marks, list the topics, the prior statement that bears on each topic, and the page. Write no question that will be asked in court as if it were the examination script to be read out. |
| What the lawyer must review | The plan is internal work product. Model Rule 1.6 and Formal Opinion 512 keep the statements and your impressions out of a public or self-learning tool. Rule 16 is why the statements are in the file in a federal case. You decide which inconsistencies matter and you do not offer evidence you know is false. Model Rule 3.3(a)(3) forbids offering evidence the lawyer knows is false, with the criminal-defendant exception stated in the rule. |
| Written for | United States |
| Applies to | [Prepare a cross-examination plan from the witness statement](https://ailawframework.com/practice/criminal-law/prepare-a-cross-examination-plan-from-the-witness-statement.md) |

## Checking plan

- What the AI does: From the statements the lawyer marks, list the topics, the prior statement that bears on each topic, and the page. Write no question that will be asked in court as if it were the examination script to be read out.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- D.C. Opinion 388 treats mental impressions as work product that remains protected even when some other work product is ordered disclosed.
- A plan is not a script to hand to the client to memorise.

## Sources

- [ABA Model Rule 1.6, Confidentiality of Information](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_1_6_confidentiality_of_information/) (checked 2026-10-22)
- [ABA Model Rule 3.3, Candor Toward the Tribunal](https://www.americanbar.org/groups/professional_responsibility/publications/model_rules_of_professional_conduct/rule_3_3_candor_toward_the_tribunal/) (checked 2026-10-22)
- [Federal Rule of Criminal Procedure 16](https://www.law.cornell.edu/rules/frcrmp/rule_16) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*