INEFFECTIVE CROSS-EXAMINATION IS ATTRIBUTED TO THREE FACTORS: THE TENDENCY TO VIEW CROSS-EXAMINATION AS AN ART, ATTORNEYS' BELIEF THAT THEY CANNOT REALLY PREPARE FOR CROSS-EXAMINATION, AND POOR UNDERSTANDING OF THE PURPOSES OF CROSS-EXAMINATION. TO ADDRESS THESE PROBLEMS, A PRACTICAL APPROACH TO PRETRIAL PREPARATION FOR CROSS-EXAMINATION IS PRESENTED, TOGETHER WITH TECHNIQUES FOR ASSURING THAT EACH CROSS-EXAMINATION INQUIRY ACCOMPLISHES ITS PURPOSE. FACTORS THAT SHOULD ENTER INTO THE DECISION TO CROSS-EXAMINE ARE DISCUSSED, AS IS THE USE OF LEADING QUESTIONS TO CONTROL TESTIMONY. A CROSS-EXAMINATION MODEL, WHICH PROVIDES A MEANS OF ASSESSING THE RISKS INVOLVED IN ASKING QUESTIONS FOR WHICH THE CROSS-EXAMINING ATTORNEY CANNOT PREDICT WITH CERTAINTY THE WITNESS' ANSWER, IS PRESENTED. THE MODEL DELINEATES AND ILLUSTRATES WITH EXAMPLES THREE CATEGORIES OF QUESTIONS: HIGH, MEDIUM, AND LOW SAFETY. THE DEGREE OF SAFETY DEPENDS ON THE ABILITY OF THE CROSS-EXAMINER TO REFUTE AN UNFAVORABLE ANSWER. FOR INSTANCE, A HIGH-SAFETY QUESTION IS ONE FOR WHICH AN UNFAVORABLE ANSWER COULD BE REFUTED DIRECTLY, PERHAPS BY TESTIMONY FROM A MORE CREDIBLE WITNESS. GUIDELINES FOR USING THE MODEL TO PLAN AND CONDUCT CROSS-EXAMINATION ARE PRESENTED. ATTORNEYS ARE REMINDED THAT IN DECIDING WHETHER TO ASK A QUESTION ON CROSS-EXAMINATION, THEY MUST CONSIDER NOT ONLY THE SAFETY OF THE QUESTION BUT ALSO ITS IMPORTANCE TO THE CASE. (LKM)