As further preparation for cross-examination, the expert should:

• Explore the literature that supports the technical conclusions.
• Be sensitive to expert/attorney communication confidentiality. If possible, have the sponsoring attorneys prepare summaries of relevant facts and documents rather than providing the documents and leaving the summary up to the expert.
• Not be afraid to develop a list of projected questions, even before counsel provides them.

The expert can assist in guiding the examination by careful preparation, including the following:

1.   Make sure there is scientific, technical, professional or other recognized confirmation for the theories that are relied upon.
2.   Test the opinion. Does it make sense? If it does not, the expert should go back to the drawing board.
3.   Be logical, simple and as brief as possible.
4.   Make sure all of the language is understandable and that technical terms are translated into laymen's terms.
5.   Whenever appropriate, prepare an illustration or perform a test or an experiment that will demonstrate the conclusion. Be liberal in the use of charts, models, drawings,   diagrams and any other device that could enhance the visual impact of testimony.
6.   Maintain familiarity with current state and federal rules regarding expert testimony and admissibility.
7.   Stay current by attending conferences and seminars on the subject, both generally and within the field of expertise.
8.   Subscribe to recognized publications on expert testimony.

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