Top Ten Things to Remember when Preparing a Medical Expert for Trial Deposition

by R. Denise Henning

10. Prepare yourself
9. Learned Treatise*
8. Use model of body part*
7. Use examples – “this injury is like”
6. Teach the medical terminology*
5. Logically present the medical records*
4. Exploit role of treating doctor
3. Address the bad medical prior to cross
2. Know your closing argument
1. Prepare your expert

* = Demonstrative Exhibit

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