I knew a lawyer who used to say that expert depositions were extremely easy. "You only need to ask a single question," he'd say. "'What are your opinions?'"
Expert depositions aren't quite that easy. Even so, there's something about expert depositions that make lawyers want to boil them down to their bare essence. It's a sort of game, like trying to prove a math theorem in the fewest steps possible.
It's in this spirit that one should read a post at the Trial Lawyer Resource Center: "Expert Witness Deposition: Five Questions To Ask." Here's most of the post--
Expert’s deposition. While there is no substitute for being prepared, you can take an effective deposition "on the fly" by remembering five essential questions and their logical subquestions:
1. Who engaged you in this case.
2. What they ask you to do?
3. What did you do?
4. What conclusions, opinions did you reach and what do you intend to testify to at trial?
It might be the world's shortest expert-deposition outline. Four questions plus a fifth I didn't include--to see it, you'll have to read the original post.
Is it a good idea to start an expert deposition with such a simple plan? If nothing else, the exercise of writing a very short outline is a helpful one, as it will force you to consider what's most important about the deposition.
I'll talk more about this idea in my third podcast on advanced deposition techniques, coming soon.