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The "Ten Categories Cross"
 (of an expert).

There are ten categories of cross examination questions that you can almost always use in cross-examining an expert witness.

Use our form to quickly think and organize your thoughts about questions in each of the ten categories. Download the complimentary (no charge to you) "Ten Categories Cross" (of an expert) form atScroll down the page, for the download link. the link half way down this page.  (The position of that link is our way of also giving you some instruction and examples of what you might do.)

Jot down, in the ten spaces provided in the form, your notes for questions each in these ten categories. Using the form not only will direct your thinking, but also encourage you to think more creatively.

For example, the ten categories include these four categories: 

  • Show the witness has limits on his qualifications.  (E.g., your case may be one in which you could ask: "You never have treated a case of Pott's fracture.....You have just read about the way to do it.!")
     

  • Do a peripheral cross-examination about the nature of his/her science and its defects.  (E.g., your case may be one in which you could ask:  "Economists guessed wrong in 2006 for what interest rates would be in 2009. ... The number you stated for the future interest rate is not a number you can guarantee, because economics is not an exact science.")
     

  • Show the witness does not have some facts. (E.g., your case may be one in which you could ask: "You did not know Jones talked to Smith, and you did not know whether Smith ever had a memo on the subject..... Even without finding out the things you did not know, you were ready to give an opinion and collect a fee.")
     

  • Make it seem that the expert is conceding some points; confirm points of our expert.  (E.g., your case may be one in which you could ask:  "You agree with our expert that the coefficient of friction of this floor was...." "So you agree with us that the coefficient of friction of this floor was ....")

Depose the expert witness with checklist of questionsThis form is designed to be placed in your trial notebook, ready when you need to build a cross-examination quickly during a trial. This is a short form, but it goes a long way  in making better your trial cross-examination of an expert.

Click to download free form. #EX0802, for your trial cross exam of an expert.


On the subject of depositions, not trial, if If you are looking for a question outline for deposing an adverse expert witness, see our 15-page deposition questions list. #EX0804 -  Deposition Questions Adverse Expert.

If you are looking for other forms and outlines regarding expert witnesses, then start at the ExpertEase™ section

Our legal forms, and other lawyer litigation tips, tactics, and tools are intended only for attorneys and their legal assistants. We do not provide legal or other professional services. Purchasers should themselves research original sources of authority and local law. If legal advice is required, seek the service of a lawyer in your jurisdiction.