BASIC EXPERT WITNESS DEPOSITION OUTLINE
- Education and Employment Background-educational background, starting at the high-school level -employment history in chronological order
-military
-special licenses, board certifications, etc.-professional societies, organizations-teaching or lectures-published articles, books, or papers-drafted any relevant legislation-done anything else relevant to the case
- Prior Experience as an Expert-How long has the expert been testifying in litigation matters, oneither a part-time or full-time basis? -How many times has expert given a deposition, testified at trial,
given expert testimony under oath in a hearing or other proceeding?-What percentage has expert worked for plaintiff or defendant?-How many cases have same fact pattern or issue?-What other types of cases have you been consulted?-Has expert testified for same law firm or defendant before?
- Assignment in Present Case-date on which expert was first contacted
- How Time on Case Has Been Spent
-How many hours?
-Spent reading and nature of what has been read?
-Spent discussing case and with whom? Counsel, parties, other experts, independent third parties-Other: examining the scene, conducting tests, examining evidence,doing calculations, writing reports-Rates, charges, and manner of billing
- File and Reports-Written reports?
- Assistance that Expert has Received-Identity of each assistant and nature of work
- Expert’s Opinions
- Bases for Each Opinion-any admissible evidence that is relied upon-any inadmissible data that is relied upon-all assumptions, conjectures, or reasoning that forms basis for the opinion-any other reasons the expert may have for reaching or holding the opinion
- Inconsistencies with Each Opinion
-encountered any fact, article, evidence, any other matter that isinconsistent with the rendered opinion
- Other Contemplated Work
