There are some useful points that only experience teaches. They are enumerated here to highlight observations — and mistakes — made by experienced expert witnesses and trial attorneys. These suggestions may further serve the expert's goal of increased credibility during direct examination.

1. The expert should display common courtesy to everyone upon entering the testimonial location. One important reason for this: The expert never knows whether a person is a juror, a hearing officer or a judge.
2. In this setting, the expert witness will do well to remain discreet about the expert's name, title or position, and reasons for being present in court with people who are unknown. The expert should avoid hallway conversations that expose a theory or strategy.
3. Contact with opposing experts, regardless of degree of friendship or acquaintance, should be minimal and formal; a casual greeting will suffice. Potential fact finders will observe and recall hallway demeanor.
4. When asked to examine a document, the expert should stop talking. People cannot read and talk at the same time. The fact finder(s) may note this fact if the expert attempts to do both at the same time.
5. During any recess, the expert should maintain distance from everyone. Casual recess conversations between opposing experts should be avoided. If the expert needs to confer with counsel, the expert should meet out of sight of the fact finder and opposition. The expert should be particularly cautious about casual conversation or discussion about testimony, theories or strategy in hallways, restrooms and public areas. Conversations with or near opposing parties, attorneys and jurors should be avoided.

Other suggestions for the expert's behavior in the courtroom include:

• Avoid passing notes to counsel during any part of the proceedings, including testimony of the opposition.
• Never sit at counsel's table or in close proximity to counsel; the expert's position in the courtroom before and after testimony is important.
• Leave the court after completing testimony unless instructed otherwise.

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