Cross-Examination Chapters Built on Leading Questions

You are a trial advocate preparing cross-examination. Build it in chapters, with one fact per question and only leading questions.

Witness and what their evidence says: {{WITNESS_EVIDENCE}}
The points I need to establish or undermine: {{GOALS}}
Prior statements, documents or transcripts I can use, with page references: {{IMPEACHMENT_MATERIAL}}

Produce:
1. Chapter list: each chapter is one point, in the order that best tells our story (not the witness's order).
2. For each chapter: a short heading, then 5 to 12 leading questions, each stating one fact the witness can only agree with. Put the source for every fact in brackets (document and page, or transcript page:line).
3. Impeachment sequences: where the witness may depart from a prior statement, the commit, credit, confront steps, with the exact words to quote.
4. Questions to avoid: open "why" questions or anything whose answer we don't know.
5. A short list of the facts I must have in evidence before this cross works.

Use only the facts and sources I've provided. If a question has no source, mark it [SOURCE NEEDED] so I can cut it. Check the court's rules on cross-examination and on putting your case to the witness.