This is not a ruling, but a list of areas where I see counsel making errors on a consistent basis. Hope it helps someone in thinking about these things.
PREDICATES often done erroneously:
Use of writing to refresh: See TRE Rule 612. The writing is only useable to refresh memory when the witness cannot otherwise accurately recall a matter. Therefore, you must first establish the necessity of that reference, e.g. "Mr. Smith, are you able to accurately recall the points made on the occasion in question?" [Wit answers "no"]. "Is there a document that would help you to refresh your memory?" That sets it up but it's frequently not done. And DONT hand it to the witness until the predicate is laid.