Today we discuss the most important details to include when summarizing an expert depo.

When you summarize an expert depo, the first line of questioning usually is talking about the background, their education, how many cases that they’ve worked on, their breakdown of work, how many plaintiffs case v.s. defendants. And then they start getting into talking about documents reviewed. So on our deposition summaries that’s our topic is: “Document Review”, or it could be “Inspections” but its mainly talking about the work that the expert has done to formulate their opinions. Then they talk about the opinions. That’s the other main topic, so it cold be they have a few opinions, it could be they have one opinion, so we put opinion one, two, three, four, so on and so fourth. And then after going through all of the opinions, the attorney at the end will almost always ask this question: “Have you giving all of your opinions today?” and please capture that as a main topic header because a lot of times if they don’t ask that question then the expert can do a lot of the work after the deposition and come to trial with stuff that the other attorney did not discover in deposition. They’re going to want to know that so you put a topic header “All Opinions Given” or “Future Work”. If they talk about future work, that gives the examining council the opportunity to set another depo date or request the opposing cousin to agree to send those records to them.

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