Another area to explore is the expert's past history as a witness. The client should be involved in the selection and retention of an expert, and before any payment agreements are reached. Be careful not to overdesignate experts. With more than one, it may become almost impossible to eliminate inconsistencies in testimony. It may be better to focus on thoroughly preparing a single expert.
Many experts are vulnerable because of lack of thorough preparation.
Quality, not quantity, is the watchword. Use care communicating It is important to use great care in communicating with experts from the outset. Assume that every conversation among counsel, client, attorney and anyone else concerning the expert's work on the case, along with all material in the expert's file and documents generated by the expert, will be discovered. It is better to look for another expert than to try to block discovery that might be embarrassing. Written reports should be discouraged at the very first meeting.