Top tips for effective cross-examination in international arbitration

Explore the art of cross-examination in international arbitration with J.P. Duffy and Raj Pillai KC (3VB). In this episode, the duo discusses strategic insights, preparation techniques, tribunal expectations, and question dynamics that lead to effective cross-examination.

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Transcript:

Intro: Hello and welcome to Arbitral Insights, a podcast series brought to you by our International Arbitration practice lawyers here at Reed Smith. I'm Peter Rosher, global head of Reed Smith's International Arbitration Practice. I hope you enjoy the industry commentary, insights and anecdotes we share with you in the course of this series, wherever in the world you are. If you have any questions about any of the topics discussed, please do contact our speakers. And with that, let's get started. 

J.P.: Welcome back to the next episode of Arbitral Insights which will discuss effective cross examination and international arbitration with Raj Pillai KC, who's a barrister at 3VB in London. I'm J.P. Duffy. I'm an international arbitration partner based in New York that acts as both council and arbitrator and international arbitration seated around the world under a variety of governing laws and arbitral rules. I participate in several hearings a year as both council and arbitrator in which witnesses are cross-examined and can offer a more American point of view on this subject. As I mentioned with me today is Raj Pillai, who's a King's Council based in London. He acts in international arbitrations and also appears in English courts and various others including the BVI, Abu Dhabi and Singapore. His role is generally as lead advocate. So he will determine strategy with the client and the legal team and then run the arguments and carry out the cross-examinations. Raj is gonna offer some insights based on both common law litigation and his arbitration experience. So welcome Raj and thank you for joining us today. 

Raj: Thanks J.P. Nice to be here. 

J.P.: So let me begin by talking about the importance of cross examination in international arbitration so that we can set the stage of it for our discussion. As many of the listeners will know in international arbitration, direct witness testimony is usually offered by witness statement and that's written witness statement. And what that means is that the witness will tell their story through a written document that has been prepared with the help of lawyers. There's a trend in occasion for some of these witness statements to be written entirely by the legal team and then signed off by the witness that can be a mistake because oftentimes it doesn't present the witness in a manner that allows the witness to seem very authentic or seem like they're offering their true factual story. Typically, the way that we like to do things is we like to interview the witness, hear their story, prepare them in at least from the US perspective in a way that we might prepare a witness for direct examination and then put their witness statement down on paper and then have them sign off on that. That's usually the way it's done in the US I should mention, I'm qualified in England and Wales as well. So we can have issues occasionally with how we prepare witnesses and the differences between the two systems. But I think that's usually the way most people would do it from a general perspective. Now, what that also means is that cross therefore becomes the first opportunity for the tribunal to really hear from the witness themselves and to assess the witness. So it's one thing and I've noticed this sitting in as arbitrator, it's one thing to read a witness statement and to get a sense of what you might think the witness is, it's a very different experience. When you then see that witness hear from them live, see their mannerisms, hear their words coming directly from their mouth, with their own timber, their own tenor and their own delivery. So cross really takes on a disproportionate value and importance in international arbitration because you've not heard from them before. Now, there's in my experience at least, and Raj may have different ones, There are rarely any surprises on cross. Although Raj and I did have an experience many years ago in Singapore where a witness um that I was crossing started to offer a lot of testimony that that no one had ever heard before. But for the most part there's rarely those sort of TV moments where someone admits to everything that they've been accused of or admits to something that's been a key issue in a case. But it's still allows you to discredit witnesses and to highlight the other party's weaknesses and the strengths in your case. So it is a critical, critical phase and a critical skill. And it's one that many lawyers, particularly in jurisdictions like the US may not have as much experience with. And just to give some background on that, statistically, the vast majority of US cases never get to a trial, which is where you would cross examine a witness in the US. Many, many, many US lawyers are very familiar with direct, which is a fact gathering exercise um because they depose witnesses, they conduct direct examinations all the time, but many do not have experience with the process of cross, which involves really testing a witness's direct testimony. It's a very different skill set and a very different approach. And notably, it can really backfire if it's done improperly. Um A good cross is highly effective and highly persuasive. A bad cross can be more damaging than no cross at all. So with that, let me ask Raj a few questions about how he approaches cross. Raj, what's the first thing that you consider when you're preparing to cross a witness? 

Raj: The first thing really is whether you need to cross them at all because as you pointed out J.P. the question is how you test a witness. Now, you gotta ask yourself, is there a point I need to make by referring uh this witness to a document, can I undermine their credibility because they've said X in their statement? And there's a document that shows entirely the opposite. Also, if you're looking at a case that involves fraud allegations, there is a different aspect to it because the way we call it, uh put it in England is that the witness should have a chance to respond to the allegation. So do you have to put the point to the witness? And there are some differences in practice and expectation in this regard between court and litigation. And I just want to pick up on one of the things you said about the preparation of the witness statement because that feeds in to how a witness will react to cross-examination. If it's too technical, if it's too legalese, then when they're preparing it in the week before the hearing, the night before the hearing, you know, they're busy people. They haven't been focusing on the case in the way the legal team does. Um, they need to be able to understand what's been said and they need to understand their story because if they can't, then they're, they're gonna be more vulnerable when it comes to the cross-examination. And that's one of the things I think it's important to teach your legal team, particularly younger lawyers when they're drafting these first cuts of these statements is don't say something that your client is not gonna be able to hold up that isn't in simple language. 

J.P.: Just on that point as well. I think you raise an excellent point, which is to say as well when you're preparing these witness statements, do it in the language that the witness himself or herself would use and don't make it overly legalistic because there's nothing worse than seeing a witness cross-examined on a phrase that they don't understand at all because they would never use it. But I've seen that experience and it's quite, it's quite embarrassing on cross. 

Raj: And it's one of those easy things to avoid. But what often doesn't happen, I think it feeds into experience both, you know, in US litigation, but also in London Court and arbitration is that a lot of commercial disputes and heavily complex, expensive, high value ones, you know, people settle them so they don't fight. But you've always got to remember as the lawyer, what's this gonna be used for in two months, six months, two years time, you know, and, and for younger lawyers again, where's this? Where's this paragraph I've written? Then next going to come to light and if it's in cross-examination, then the witness needs to be able to uphold it. So we're talking about, um, whether you need to cross examine and the key thing is what you need to get out of the other side's witness to make your case go forward. If there's fraud allegations, you might need to put those points and say you lied on this and then you take them to the evidence that supports your case and why you say they lied. But particularly in arbitrations, there is some flexibility about that. Really think as an advocate, you've got to focus on what's important because you might have very long witness statements, you know, with 50 factual disputes of which only two or three are important. And remember time is often tight in an arbitration, you're gonna have slots for each witness because of their availability and the and the tribunal's availability. So really uh make sure you can focus on the key points and also don't ask questions to which you don't know the answer. We're gonna come to this in a little bit. Um But you don't want to allow witnesses to correct weak points in their evidence. So don't ask questions which give them an easy goal. And also there will be a difference which we'll pick up on between factual witnesses. Those are the ones who were involved in things that happened at the time. They're telling their story and expert witnesses who are generally brought in to assist the tribunal with their notionally independent expertise on a given technical area like valuation or technical specifications in the particular sector. 

J.P.: Yeah, Raj, you raised a few excellent points and one I just wanted to pick up on that I'm sure we're going to hit on more later, is being really selective about what you cross the witness on and you made a really good point about not allowing the witness to correct weak points. Um, and one of the things that comes out of that, that I'm sure we'll talk more is when you oftentimes read through a witness statement, you will see things that are occasionally glaring errors and sometimes those glaring errors are ones that would be easy to pick apart on cross. Other times, you just want to leave them alone because it's much better to address those in written submissions and point out the glaring inconsistency than allow the witness to go back and say, oh yes, I misspoke or yes. What I really meant was this and I think that's what you're getting at. It's a real art form when it's done well. Um But it's, it again, goes to your point about being, being selective. Now, Raj, what are some of the other things that you consider um when you're preparing for cross examination? 

Raj: So I, I think we're gonna come to it. It's about preparation. But one of the aspects of that preparation is picking out by analyzing the legal case and the documentary record, what you need the tribunal to understand what documents they need to have seen. You won't always get a chance in a, in a compressed hearing or a timetable to have brought that out in a, in a long opening speech or similar. So with a witness, if they've written the key email or they were copied in on the email and, you know, you could expect them to have responded. If it was important to them at the time and their account differs in their witness testimony, then you've got to make sure that you're gonna bring those out in a, in a carefully planned cross examination. Sometimes that can be thematic. Uh But otherwise it might be chronological depending on what sort of case you've got. And you've got to do it at a pace and, and with a clarity that allows the tribunal who won't be as well prepared as you and won't be as well prepared properly as the witness to understand and to follow. Ah, I see this email fits into such and such. That's the aspect of the case this goes to. So you don't want to leave them behind and you've got pace it accordingly and check that you're bringing the tribunal along with you. 

J.P.: Yeah, those are, those are excellent points. And, you know, if I were to sort of summarize that, I think really what you want to do is be pick a few key points that you need to hit in your cross-examination. And this is something I know we're going to talk a lot about. But you have to go into these with a clear strategy, objective and knowing exactly what you want to accomplish. And sometimes you can accomplish it clearly right away. Sometimes it may become apparent from speaking with the witness that you will not accomplish certain things, but that other things will be easier to accomplish. You really do need to understand what you're trying to get out of the witness and to make those points accessible to the tribunal. Because if you don't, it becomes a rather long exercise in confusion. That can be, that can be really, you know, really a waste of time. And your, your point about addressing key points in your case is really, you know, it seems axiomatic and it seems obvious, but it's amazing how oftentimes parties start crossing on points and either the tribunal or opposing counsel sitting there staring dumbfounded because they have no idea why you're getting at something. Um, and wasting time on meaningless points is really an ineffective way to go about it. 

Raj: When that happens, when my opponents start doing that, I'm entirely relaxed about it because they're wasting their own time and the tribunal will spend a couple of minutes thinking where are they going? And then, you know, they'll pick up on this being a waste of time. They'll switch off, you know, when you see them going glazed over when your other side is using up their time. That's perfect. 

J.P.: Yeah, that's exactly right. And you, you also hit a point that I think we're going to talk more about, but it's really, you have to understand your tribunal when you're doing this. Um It's really key to understand the background, the legal, the legal tradition from which they hail what type of experience they have with both hearings and cross-examination. You know, it can be the case that you can have a tribunal member who was not a practicing advocate and that party or that tribunal member may well not understand the purpose of cross or may not see cross the way that you do. You know, we talked in advance of recording this about, you know, perhaps having a uh a tribunal member who hails from a different civil law tradition that would not use cross or would not understand it. So you really do need to understand, um you do need to understand your tribunal and in that regard, you really need to understand the witness too. You know, some, every witness is different, just like every person is different. Some can be more combative, some can be more talkative, some can be more cagey and you may or may not know that going in. Oftentimes in the types of cases that Raj and I do the party that you are representing as the advocate will have a very good sense of what type of person the witness is because they will have dealt with them a good deal, but that's not always the case. So you really do need to fill out the witness as well. Let's then talk a bit about because we were talking about how to do this effectively. Let's talk about some of the steps that we take to prepare for one of these. And the first one again is, seems obvious, but it's one that gets lost on occasion and it's really to prepare thoroughly. You really need to know all the key facts and all the key documents in order to effectively cross examine someone. It happens where you see someone who's pulled into a case at the last minute or they've not thoroughly prepared themselves, they've left the preparation of someone else or picking up and they will start a cross-examination and they will ask a question and that question, will there be in artfully asked or they will miss an answer. Um You know, the witness might have given an answer that would lead to a new line of questioning or a key admission, but they've not picked up on that because they've not known all the facts or they will simply ask a question that's inadvisable. You know, as Raj said earlier, don't ask a question to which you don't know the answer. Um That happens and that happens when someone's not prepared. And you, so you really need to know all the key facts of the case and the documents. You need to know the witness statements cold both the witness that you're cross-examining and the other witnesses in the case. If you don't know what the other witnesses have said, it's very, very difficult to effectively cross examine the witness in front of you, and Raj, I'm sure you've had this experience where you've seen someone make an admission that's addressed in someone else's witness statement, but an advocate hasn't necessarily picked up on that because they've not fully prepared the case. Have you ever had that, that happened in a case for you? 

Raj: Not on my part, but it, it occasionally happens on the other side. I mean, I've never had it happen on a crucial point because generally, you know, we've been talking about the big picture things. Um But yeah, you do have that and equally, you have witness statements which just have verbatim, same chunks sometimes just cut and paste it and there you trust the tribunal as well because you make the point softly, it's all there. But yeah, it's, it's all about the preparation. 

J.P.: Yeah, that's right. And I think, you know, part of part of this to a, a preparation is having a game plan for how you're going to go about each witness, right? And that again seems obvious, but you need to go in with not just a set script because every script will deviate instantaneously, but a game plan that understands where you need to get to and how you plan to get there. But you need some flexibility for how you're going to do that. Now, one effective practical way to go about that is to consider making a bundle for each witness, right? So if you know that you need to hit three points with a certain witness and that three of those points are going to be addressed by five different documents, have a bundle together of those five documents that you can give the witness in advance, that you can give to the tribunal and have copies for the other side as well. So that you can effectively move through that part of what we're going to talk about as well is the pace and the tenor of cross and how you control a witness, which is something Raj is going to address next. But part of how you control that witness is the pace at which you move, how quickly you're asking questions and the tenor by which you're doing it and having a bundle of documents for that witness to address without giving them the opportunity to pause thumb through things, go searching for documents in the record. It really adds to the effectiveness of cross. And the last thing is is we talked about know the witness themselves, we touched on this a bit earlier, but to the extent you can get as much intelligence in advance about the witness, how talkative they are. Um you know what type of culture they come from some cultures, some cultural backgrounds may be that people speak less, some cultural backgrounds, maybe that some people speak more, you know, some people may be more aggressive, less aggressive, those are generalizations. But it also comes down to the individual. Obviously, you know, any individual can be um combative, can be shy, can be meek. You need to understand that as quickly as you can, the best way is to get intelligence in advance. But you will also start to suss that out as you cross examine the witnesses themselves And we're going to talk about this more too. But you can also encourage those types of responses by the manner in which you cross examine someone as well. So we talked a bit about, we started to touch on controlling the witness. Raj, why don't you give the audience a bit on the importance of controlling the witness and how you go about it. 

Raj: So a witness comes to the court of tribunal to tell their story. Sometimes it's their chance of having their day in court. Now, tribunals and courts are not that interested in which uh in witnesses giving speeches. So what you want to do is have a clear strategy and line of questioning that doesn't allow them to deviate and go on to points that are either irrelevant and are wasting your time that are dead ends, which are also wasting your time or otherwise are giving them a chance to make their position better than appears on the documents they prepared beforehand. So you want to get the key evidence on the transcript and do it as efficiently as possible. And you're always going to be under time pressure because as we've said, claims run on timetables, you know, the witness, when they go, they're gone, you're not going to get a second go. Um, and, and the key is to remember, you're in charge as the cross-examining advocate, nobody else knows where you're going to go. Now sure you'll see, particularly in our line of work, some very confident individuals coming to the stand. But you know, sometimes that confidence can be their own weakness, cos they will try to assume that they know what your story is, the line you're taking and they will try to prejudge answers and jump ahead sometimes to show how clever they are. But often always just to keep telling their story and spin it. Our tribunal, particularly an experienced one is unlikely to be impressed by attempts to speak or attempts to jump ahead or second guess. But you will always ultimately have to let witnesses finish their answers. We, you know, we'll touch on being respectful generally towards the tribunal, but also to the witnesses. So don't try to cut them off, particularly if they're giving an answer that you feel will damage you. The best thing to avoid damaging answers to is to adopt a technique that doesn't encourage wide ranging or long winded answers. So we say use leading and closed ended questions, things that have a yes or no answer or as narrow a scope. So not what did you do yesterday, but more at four o'clock PM, you'd sent this email which showed that you are at such and such, hadn't you? So that you focus on a narrow answer. Keep the question simple. Usually, generally get going with uncontroversial matters so that the witness has to agree. And one of the, the classic instances of, of trying to trap them is to you have four or five questions. So they agree. Well, if this concept was right, then it must be the following concept was right, then the third concept and then finally, they've got no way nowhere to go when you hit them with the final document to the final point. And if they do try to bluster out of that, that of itself will make them seem unconvincing. J.P. has already touched on controlling the cadence and speed of the questions. And that also includes giving them a chance to respond fairly because as, as J.P. touched on the concern of tribunals from different contexts and different experiences and different legal cultures, they will sometimes look askance if you are too abrupt with a witness or you don't give them a chance to respond to a question. After all, it's got to be a two way street. Keep up your eye contact with the tribunal so that you can see that they're coming along on your journey. Um and sometimes be flexible. So if you haven't got an answer you want in a particular way, you may need to come back to it in order to ensure that you have got the point out. But that's really what we're talking about control is to make sure that they're not given a chance to ramble on in a freestyle. There are some very limited examples where you've got a witness is garrulous and you know, or you, you think from how things have been going, that they might get themselves into trouble by talking too much, you know, by undermining um some of the the narrowly constructed legal arguments they have been given so it can assist your case to let them speak at a certain point. But you need to um you need to be sensitive about that and that's got to be in the right situation because generally I think control is the key. 

J.P.: Yeah, I agree and you raise excellent points Raj and part of that control is listening to the answers that they give, right? And you, you mentioned that, but when a witness gives an answer that you may or may not expect that can open any number of new questions, it could really be problematic for them. And if you know your case and you thoroughly prepared, that becomes very obvious, but it is very, very important in that case to listen and to actively listen. Um It's amazing how often, how often times parties are ticking boxes um asking questions, not, not listening to the answer and then just moving on. And you're thinking as the tribunal member, wow, there are 10 questions. I would have loved to hear the answer to there. Um And in international arbitration, unlike some courts, it is likely that the tribunal may circle back and ask those things and if you have not asked them the way that you want to, you may not get the answers that you were hoping for. Um So really, really important and that is a big, big part of controlling the witness. There is no better way to really, really, really control a witness than to take what they've just said and follow through on it. It creates a connection with them. Um It controls the cadence of things and it allows you to be in charge as Raj said, of the questions are being asked. So do actively listen. And you know, Raj's point about keeping eye contact with the tribunal is a great one. You need to be following through to see what the tribunal, how the tribunal is reacting. But in the same token, make sure you're keeping that contact with the witness as well. You know, it's a very basic animalistic dominance thing. But looking someone in the eye while you're questioning them can truly, truly help you control how the questioning goes and how the answers go. Now, Raj, you talked a bit about being respectful. Can you just explain that a bit further. I think that's a really a really critical point. 

Raj: Yeah. Uh, the tribunal or a court in, in a complex commercial dispute is really there to get to a fair outcome, to get to the answer as efficiently as it can. Right. It's, it's a commercial, practical exercise. Expensive, sometimes long winded. But that's what they're trying to do. And they don't need grandstanding and they generally don't like disrespectful questioners and they don't like grandstanding council either. Disrespectful questions were counselors rude to a witness can make it harder to control the witness because they may have an emotional reaction to it and really sidetrack the entire process. Uh And it can also break the flow of what you were getting to with your transcript. We talked earlier about building up questions and trapping witnesses. But if you have gone too hard on something, then that can break it all up and, and worst of all, if you get told off by the tribunal that's on the transcript that you know, that doesn't look professional and it isn't helping your cause or the client's cause. And I, and I think J.P., this is one of the things you, you'd picked up before when we were having the discussion, it conveys your weakness to the tribunal as council. It undermines your position because the tribunals, I'm thinking, why is this guy playing tricks rather than just getting on with it and helping us get to the bottom of this problem and just take a step back. If the questioner asks a series of questions without really paying attention, you're rattling through it. If the questioner plainly hasn't got control of a witness or is rambling a bit, that makes me as a tribunal member or a judge lose faith in the questioner. And it's a real show of confidence from your advocate where they ask fewer questions are more incisive. Don't ramble. They're clean and when they hear their answers or if they get a good answer for them, they're not fist pumping or looking back at their team or looking triumphant, they just carry on and equally and we've all had this, you ask a question, you get a bad answer for your side. You know, the witnesses, you has got a better position and, and gives a good answer that hurts your case. Then you've gotta shut that down politely and quickly and move on without grimacing and, um, you know, smashing the desk or something, you've just gotta be grown up and move on and be professional. But all of these are things that, uh, are important for the advocate and when you're a client, you've gotta see that from your advocate. 

J.P.: Yeah, I agree. And I think one, you know, one thing about that, that I would simply add because I think it is, it, it's an excellent point is you do again need to understand the cultural differences. So, for instance, as Raj said earlier, there's a notion under English law of putting it to the witness when you're accusing them of fraud or lying in US practice, that is the exact opposite of what you would do. Um You take the witness directly to the edge and you stop right there in English practice, you do have this notion of saying, well, I submit to you, sir, you're lying about XY and Z or it can be done that way. It doesn't have to be done that way. But you do need to understand your tribunal again because if that's done improperly, if that's done in a manner that seems disrespectful to the tribunal, not only can it be ham handed um but it can be highly, highly damaging. Um conversely if you've not done that in a way that it's expected by the tribunal that can come off as weak as well. So those are all, you know, we could, we could go on for hours because luckily Raj is a highly, highly, highly experienced counsel. But I think it's useful now to move on to effective tactics with experts. You touched earlier, Raj on the difference between cross-examining fact witnesses and cross-examining experts. Perhaps you could just talk a bit about how you effectively cross an expert when you're posed with that challenge. 

Raj: Sure. So we talked about fact witnesses being there to tell their stories, an expert will generally be there to deal with. Uh something specialist and technical such as um working standards in a given industry, perhaps a valuation of a shareholding or a business for the purposes of future business claims, lost profits and so on. Generally, they have no skin in the game. You expect them to be independent and they're there notionally to help the tribunal. Though of course, each side generally has their own expert. So they give a professional opinion based on material they've had provided them. So the key areas of attack think are usually threefold. Firstly, expertise and competence, are they actually experts in the field? Second methodology. So have they used the up to date methodology for evaluation the right um comparators and so on for a particular sector, have they drilled down into all of that detail properly? Thirdly uh their attention to detail and the material have they taken into account everything that's important in, in in the material? And then I think there's also a final sort of step back when you're looking at an expert is looking in the round. Is their outcome reasonable in a case where an infrastructure project never, never got built. Is it reasonable for them to say there would have been $7 billion of damages if this had been built so on and so forth. Um And I mentioned that we expect experts to be independent but sometimes they cross the line and they'll go into fight for, for the party that appointed them uh and if an expert is partisan, then you can point that out. But you do that by showing generally how unreasonable and how, how on every or on a majority of options, they've already always taken the one that's favorable to their client. Now so the main challenge when you're cross-examining an expert is that they're experts in that field and you're not. So you need to prepare with as much care as you would for any other witness. But also rely on your own expert from the outset to assist in developing the questions. And then most importantly, knowing what your follow-ups are. So it's almost like a flow chart or decision tree. If X then you go to this question, if Y then you go to the next question. And in some instances, you really have to delve into the detail. When I've cross examined um on financial models, often you have to get your expert to teach you how the spreadsheet was set up to go into the cells to show where the formula were wrong, to show where something was hard coded where it shouldn't have been. And often you need to have a few practice runs to ensure you get it right and then do it clearly and effectively because just as with your fact witnesses, you've got to bring the tribunal along with you on an expert witness. And often times a court or tribunal may not be the most technically minded. So then you've got to pitch it at the right level and take them to what you need to so that they can see it and understand the point that you're trying to make. For me, it's the same. Therefore, building blocks as with the fact witness be methodical. Keep it simple and ensure those building blocks are clear as you go through the cross examination. And uh finally, when you're preparing that cross-examination, again, often you're facing very thick reports with lots of appendices and schedules. You've got to ensure you've got the key points because that's really what's gonna get you home. You're not gonna be able to address 100 points in half a day. So make sure you know what the key points are on, methodology, expertise, so on and so forth. And that's in my experience is gonna get you the best outcomes. 

J.P.: Those are excellent points, Raj. And I think if I could just add one personal insight is don't quibble with experts. Um It is when you're, when you're cross examining an expert witness, you need to be highly selective about what you're going to cross upon and you need to be extremely careful about not getting sucked into an argument with an expert about their area of expertise because you will invariably lose that argument. Um It's very apparent to tribunals when that occurs. Well, this is great Raj. Thank you so much for all your valuable insight. I think we actually probably have enough material that we could come back and do a follow on one with a few more, a few more additional points. So we will certainly, I reserve my right to call you back as I, as I would like to say, well, good. Well, that concludes our discussion of effective cross-examination and international arbitration. I want to thank our guest, Raj Pillai for his really invaluable insights and his helpful comments. And I want to thank you for listening. Please do tune in to our, to our podcast and we look forward to having you um having you back Raj in the future to continue talking about this really critical subject. 

Raj: Thanks very much J.P. 

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