Areas of Inquiry in Cross-examination.



Qualifications - Stay within your area of expertise

Knowledge of the facts of the case - Direct /Indirect
Prepare a timeline - Be familiar with the basic facts of the case such as: times, dates, places, results of tests, etc. Don't be a "Dr. Golden"!

Bases or foundations of your opinions
Studies you conducted or data upon which you typically rely (FRE 703)

Degree of certainty - How certain are you?

Completeness of your review - What didn't you see?

Bias - Personal, financial or otherwise
Fees, number of times worked for the same law firm, number of times worked for Plaintiffs v. Defendants, etc.

Integrity - Tone, innuendo, or sarcasm in questioning, advertising practices, "hired gun" assertions.

Use of "authoritative" texts and "learned treatises" for impeachment.

Attempts to gain "admissions" or "concessions."
Isn't it a fact that...? Isn't it possible...? Hypotheticals - if X then Y? Couldn't you have missed something important in your review? ?