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not give such information as you have. If a "yes" <br />or "no" answer to a question is demanded but you <br />think that a qualification should be made to any <br />such answer, give the "yes" or "no" and at once <br />request permission to explain your answer. Don't <br />worry about the effect an answer may have. Don't <br />worry about being bulldozed or embarrassed; <br />counsel will protect you. If you know the answer <br />to a question, state it as precisely and succinctly <br />as you can. The best protection against extensive <br />cross-examination is to be brief, absolutely <br />accurate, and entirely calm. <br />In order to present material in the most favorable light, a witness must <br />reflect possession of knowledge in a calm manner. No matter how intelligent <br />the witness may be, adoption of an argumentative stance serves only to harm <br />the credibility of the witness's testimony. A witness may become irritated by <br />the questions directed toward him or her, but this must not become apparent in <br />the testimony given, nor should the witness allow such irritation to be <br />expressed in the form of argumentative responses. This problem is illustrated <br />in the following material derived from the Yellowstone River Reservation <br />proceedings held before the Hearing Officer for the Montana Board of Natural <br />Resources and Conservation (Montana Board of Natural Resources and Conserva- <br />tion August 9, 1977:63-64). <br />Q. All right, so you do consider that answer to <br />be a reasonable one, 1282 gallons per capita per <br />day? <br />A. Including industrial uses in the manner that <br />you are using it, I would assume it's reasonable. <br />However, I did not make that statement; that was <br />the per capita usage that we were projecting for <br />our residents. <br />Q. O.K., keeping that figure in mind, on page 1 <br />of Exhibit 4, you indicate that personal water use <br />rates at 320 gallons per day as average and 896 <br />gallons per person per day as your maximum? <br />A. Yes. <br />Q. How do you reconcile the difference? <br />A. Well, that's what I've been trying to tell <br />you. Thirty percent of that 1190 is for industrial <br />purposes. <br />Q. And is it not correct that you said you did <br />not factor in certain other industrial developments <br />in that 30 percent contingency reservation? <br />A. I used that as a total amount for future <br />industry that would come to the City and need <br />water. <br />16