I feel that the collateral information about an expert which indicates bias is more important in cross examination then the issue involved. If you can show a lack of credibility then the opinions of the expert have little weight with the jury. Here's a simple check list of reminders to ask at the time of the deposition for you to consider

ADVERTISING FOR WORK

 

• How became involved in this case
• Does advertising for work
• Belongs to expert witness group
• Any past connection defense firm
• Any past connection defendants

EXPERIENCE AS EXPERT

• How long acted as expert
• Experience - frequency:

               a. cases reviewed
               b. reports written
              c.  depositions given
              d.  times testified

• what states testified in
• What percentages for  plaintiff vs defendant

FEES CHARGED

• For review
• For deposition
• For testimony

INCOME FROM EXPERT WORK

Highest fee ever earned in one case?

Income last year from expert work

Average annual income from expert work

TORT REFORM ACTIVITY

• What political activity
• Letters or emails to paper, media or legislators
• Contributions made
• Literature in his office about it

WITNESS CONSULTANT

• Any consultations with non lawyer re being witness
• Videos watched or information given

KNOWLEDGE ABOUT LOCAL MEDICAL STANDARDS

DEFINITIONS USED IN ARRIVING AT OPINIONS

What is your definition of these terms as it applies to your opinions here:

• Medical negligence
• Malpractice
• Medical standard of care
• Reasonable medical certainty