Deposition outline-medical/mental health professional

1. BACKGROUND AND PRELIMINARY QUESTIONS

   1. Identifying Information

      1. Full name, address and telephone number.

      2. Driver’s license and Social Security number for background investigation.

      3. Description of profession and job title.

      4. Identify current employer including address and telephone number and length of employment.

   2. Education History (obtain a resume if available)

      1. Identify education and professional training.

      2. Degrees, certificates or professional certification and licensor.

      3. Confirm dates of certification or licensure and where obtained.

      4. Describe the significance of each certification and what type of practice it allows.

      5. Have any of the experts’ certifications or licensors been suspended, revoked or limited?

      6. Any on-the-job training or employer-related training or certification.

      7. Honors or appointments.

   3. Published Writings

      1. Identify all publications (focus on any published writings or works related to the subject matter of a lawsuit).

      2. If expert’s resume not available or does not contain published works, detail each publication, date published, where published, co-authors and availability of copies.

   4. Research

      1. Identify all research, focusing on research related to the subject matter lawsuit.

      2. Identify collaborators and institutions or sponsoring entities.

      3. Identify all writings or publications of research results and analysis.

      4. Determine availability of written documentation of research conducted.

   5. Employment History

      1. Identify each employer (focus on employment history related to expert’s subject area).

      2. Identify time periods of employment, positions and job titles.

      3. Describe capacity of employment with each employer including responsibilities and functions.

      4. Determine the reason for each change of employment.

      5. State whether witness has ever been suspended, terminated, disciplined or sanctioned by any employer.

      6. Verify total percentage or length of time during professional career related/not related to subject matter of witness’s opinions in the case.

         Describe the nature of your professional practice.

      7. Describe the types of therapy or treatment rendered in practice.

      8. Describe the types of patients treated (eg. children, adults, general family practice, etc.).

      9. Explore any limitations to the witness’s practice (i.e. if the witness is not a psychiatrist, they can’t prescribe drugs, their certification may impose limits on what they can do and who they can treat).

      10. Explore the types of testing the witness is trained in administering and the types of testing the witness is not trained in administering.

   6. Professional Organizations and Affiliations

      1. Identify each professional organization to which witness belongs.

      2. Focus on organizations related to subject matter in lawsuit and determine criteria for membership and status of membership.

      3. Review resume and question witness regarding any affiliations with organizations which may be controversial, discredited or a spouse positions adverse to the opinions of the witness.

      4. Determine whether witness’s membership in an organization has ever been suspended, terminated or scrutinized.

      5. Identify any leadership positions held in any organizations.

   7. Litigation

      1. Prior deposition testimony.

      2. Prior trial testimony.

      3. Identify each instance in which expert has been retained to give testimony (include identification of names of parties, names of attorneys, location of lawsuit, etc.).

      4. Identify and discuss each instance where expert addressed similar issues to subject matter of case in question.

      5. Determine in each instance whether the witness was retained by the plaintiff or the defense.

      6. Is the expert aware of any instance where his/her testimony has been struck or limited by a judge?

      7. Does the witness maintain copies of any deposition transcripts or written reports?

      8. Does the witness maintain a list of prior litigation?

      9. What percentage of expert’s yearly income is derived from litigation/consulting work?

      10. Does the witness advertise his/her services?

      11. Does the witness belong to any referral services or networks?

      12. Has the witness ever been a party to a lawsuit? (If yes, obtain details.)

      13. Does the witness belong to any organizations...