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.

Dr. Craig JernerDr. R. Craig Jerner, Ph.D., PE specializes in accident investigation and metallurgical failure analysis, with over 30 years experience as a metallurgical consultant and accident investigator. He has testified as a metallurgical expert in over 250 depositions and more than 70 court appearances. If you or someone you know should need the services of  Dr. Jerner and J.E.I. Metallurgical, please visit our web site at the buttons below, or e-mail Dr. Jerner --- r.c.jerner@metallurgist.com


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