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.
the complimentary (no charge to you) "Ten Categories Cross" (of an
expert) form at 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
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 ....")
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
your trial cross exam of an expert.
the subject of depositions, not trial, if If you are looking for a question
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
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