Direct Examination Outline: Plaintiff's Economist in Employment (and P.I. Cases)
DIRECT OUTLINE: ECONOMIST/RE: PLAINTIFF’S ECONOMIC DAMAGES
INTRODUCTION
Name
What is your occupation
How long have you lived in _________
Did you go to college
Where did you go to college
Did you receive a degree
What were your majors
Did you do any education beyond undergrad
Ph.D.
What was your Ph.D. in
Economics
___________________________________________________________________________
When did you receive your Ph.D. in Economics
Do you have teaching experience in Economics
Work for Companies
In addition teaching, ever done any economic studies for companies
What did your work for __________ co. involve
How did co. use this info
Impacted multimillion dollar decisions
How much money this involve
How long did you work/consult for __________ co.
Current Employment
Where do you currently work
What do you do for _____________
Whom typical clients
Do attorneys ever hire you
Do Plaintiff's attorneys hire you or Defendant's attorneys hire you
Both
In addition to consulting business, do you still do any teaching work
How long have you been teaching at ____________
Summary of Qualifications
____ years full-time college teaching and research
____ years part-time teaching
____ years providing economic forecasting for companies
____ Major studies for universities, cos, governmental entities
Résumé
-- [Offer Into Evidence] B
-- [Tender Expert, if required by the applicable rules of procedure] B
Labor Economics Experience (if employment case)
What is Labor Economics
Study of job availability
Study of wage and income patterns
Study of failure rate of companies
What experience do you have in Labor Economics
Taught courses
Director of a manpower training study
Who hired you
Do you have knowledge and experience about how workers find jobs today's market place
Failure Rate
Have you studied failure rates of business
Economics Experience Assessing Damages
How many times done study similar to this
_____ times
Have you Testified in Court
Have you been qualified as an expert in Court
How many times you testified in Court
Areas in which you have been qualified as an expert
Have we ever worked on a case for me before
What did I ask you to do
___________________________________________________________________________
Work Done on this Matter
Work That You've Done to Prepare for this Case
Have you talked to ____________
Have you reviewed ___________'s income tax return
What years have you reviewed
_______ thru _______
Have you reviewed his W2s, wage statements and other information about the earnings that he has had since he has left Defendant=s employ
Have you reviewed insurance, medical and health benefits that were provided by Defendant
What else have you reviewed
The Depositions of _____________
Information re failure rates of business
U.S. Dept Commerce's, Bureau of Census: County Business Patterns
...
To continue reading
Request your trial