exper t
er
parat ion
Even experienced litigators can miss
key steps when preparing an expert for
deposition—and even the best witness
can make mistakes that trip up your case.
Use this step-by-step plan to show your
witnesses the way.
By
|| Christian C. Mester
IT’S A TRUISM that in litigation, preparation is key to everything. This saying
holds true for your expert witnesses.
They may be knowledgeable, and they
may be the top experts in their field,
but if they aren’t ready for the rigors of
deposition, their errors can damage your
carefully built case.
When preparing experts for deposition in med-mal cases, I have always
laid the groundwork thoroughly—or so
I thought. I studied their opinions, their
biases, and any angles I expected defense
counsel to take. Yet, I still found experts
mishandling questions, even easy ones.
After learning certain lessons the hard
way, I created a step-by-step process for
ensuring that I cover everything and
