Direct examination outline: plaintiff's economist in employment (and personal injury) 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

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