Conduct Your Entire Expert Cross as a Sharply Directed Controlled Cross.
Conduct your entire cross examination of the defendant’s expert as a sharply directed, controlled cross examination. At the outset have their expert admit that she is prepared to give her full and final opinions at the deposition today. Use both constructive and destructive cross. Do not permit their expert to explain or elaborate until the end of the deposition, until after you’ve asked all your questions and gotten all your expert concessions.