Deposition Exhibits
If you want to tie the hands of your expert, at least temporarily, and probably increase litigation costs, there is one thing that you should do. Send your expert poor copies of "fact" and "opposing" expert depositions and deposition exhibits.
Most of the expert depositions I get are without exhibits. Usually, I will call and ask for the exhibits to the deposition, wait for them to arrive, only to find that the photographs are 4th and 5th generational copies.
As a suggestion, please include first generation, (yes, get them directly from the court reporter!), deposition exhibits. Also, try, if at all possible to get CD's of photographs or at least first generation prints and not copies of copies of copies.
Having good deposition exhibits may cut down on your experts need to re-read and re-read all of those depositions AFTER he/she gets the exhibit.
To read more on "Working with Experts", click here.
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