SCRIPT / GUIDE

(Counsels appearances)

J: Your witness counsel?

P: Your Honor, may we call to the witness stand the 4th witness for the prosecution Dr.
Truman Serrano.

(Swearing in of the witness)

P: Your Honor, with the kind permission of the Honorable Court, the testimony of
the witness is being offered for the following purposes:

1. To certify that the undersigned on May 27, 2017 has seen and evaluated
Ms. Risa L. Robles and diagnosed her to be suffering from Acute
Stress Disorder, secondary to the alleged molestation she received
from a certain Antonio Diaz, her co-worker sometime last May 21,
2017.
2. To certify that the witness is an expert in this field.

The witness will also testify on all other matters which may be relevant to the case. May
the counsel proceed, Your Honor?

J: Proceed.

P: Good afternoon mister witness. Can you please tell this honorable court your name?

W: Yes. I am Truman D. Serrano.

P: What is your occupation/profession?

W: I am a Psychiatrist.

P: What is your educational background?

W:I have studied in..

P: What degrees, certificates, or licenses do you have?

P:Have you attended or conducted continuing education seminars, conferences and
related training?

P:Are you a member in any professional organizations/societies?

P:Have you received any awards or other professional recognition?

P: Can you please enlighten this court what acute stress disorder is?

P:How many cases involving Acute Stress Disorder have you handled?

P:How many years have you worked in this field?

P:What it is about sexual abuse that requires an expert to explain?

P:What is it about this case that a lay person with no background in this field might not

understand?

P:What are the key principles that a person without education or experience in this field

would need to grasp in order to understand this case?

P:Can you explain the scientific principles involved in this field of study to a non-expert?

P:Do you believe your testimony will aid the judge in understanding the facts in this
case? How?

P:Have you examined or interviewed the girl named Risa Robles?

P:Have you administered any medical or psychological tests to the person?

P:Have you reviewed [medical records, injury, police reports, persons written or
recorded statement, or other evidence?

P:Have you made a diagnosis regarding cause of injury or made a diagnosis with respect
to the persons needs or other issue?

P:Did you rely on any other source of information in forming your opinion other than the
examination, interview, records, etc. that we have not discussed? If so, what other sources
did you rely on?
P:What theory/technique did you base your opinion on?

P:How did you test this theory/technique?

P:What were the results?

P:How many times have you used this theory/technique?

P:Have you always used the same method when you used this theory/technique?

P:Have you ever had different results- or results inconsistent with the theory/technique
you based todays opinion on?

P:Does any part of the theory/technique require subjective interpretation? If yes, describe
what facet of the testing is subjective. If yes, do you believe another professional might
interpret the same data differently?

P:Is there any method you use to assess the subjective component of this
theory/technique?

P:Did you use that method in arriving at your opinion in this case?

P:Has there been peer review of your theory/technique?

P:Has the theory/technique you rely on today been published? If so, where & when?

P:Have any articles or other publications criticized or cast doubt on your

theory/technique?

P:If so, when and what was the basis for the criticism?

P:Does that criticism change your opinion in this case? Why not?

P:Does your theory/technique have a known or potential error rate?

P:If yes, what is the error rate?

P:How did you calculate the error rate?

P:Have you considered alternate theories or explanations?

P:Why did you reject any alternate theories or explanations?

P:Is this technique/theory generally accepted in the scientific community of

[engineers/physicians /coroners/other]?
P:What evidence is there that this is a generally accepted technique/theory?

- Formal statements of professional organizations

- Professional literature, training, publications

-Use by government/trade/community organizations

-Use Outside Courtroom

P:Is this technique/theory used for a purpose outside the courtroom and litigation?

-Diagnosis, treatment, social work assessment, criminal investigation

P:What is your field of expertise/specialty?

P:Within the [mental health/social work/social sciences/other discipline] field, is this a

recognized professional area of expertise?

P:Are there published articles recognizing this field of expertise/specialty?

P:Has this field of expertise/specialty been recognized by any licensing or accreditation

body or any governmental agency?

P:Are there professional journals or conferences that focus on this field of

expertise/specialty?

P:Is there controversy within the profession about the efficacy or reliability of this field
of expertise/specialty?

P:If so, can you articulate why these [opinions/statements/criticism] should not
undermine the value of your opinion?

P:Repeat questions related to QUALIFICATIONS, above, as needed to establish the

specific expertise and experience.

P:Based on your education and experience, are you able to give an opinion as to Risa
Robles?

P:What facts or evidence did you rely on?

P:Did you rely on [observation/examination/review of records/photographs/written or

recorded statements/reports/ tests/other]?

P:Is this the type of evidence relied on in the ordinary course by professionals in your
field?

P:Is there any other evidence or information relied on in the ordinary course by
professionals in your field as part of making such a determination that you did not use?
Why not?

He is now ready for cross-examination Your Honor.