Over at Houston Litigation blog, there is an article titled "Presenting Witnesses for Deposition." In that article, I found the section titled "Prepare the witness early and often" particularly helpful. Mr. Newton lays out 4 simple steps for properly preparing a witness, and I provide synoptic quotations below
"The first step in witness preparation is preparing the witness on the facts. ...
Second, the witness should be prepared on the law of the case. ...
Third, the witness should be prepared for the other lawyer. ...
Fourth, the witness should be prepared to give good testimony. ..."
Although he does not specifically refer to expert witnesses, I would hold that the same, or perhaps similar, process applies. Remember not to assume that other people have the same knowledge or training as you. As a lawyer, what you know to be "basic" or "common," the expert may not be aware. Think of yourself as a Rule 702 legal expert there to assist your economic expert in understanding the environment in which he or she will be operating, and how that environment applies to their work. Together, your combined training may achieve more than what you could each expect to achieve in isolation.
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