The other side's expert is only as strong as what you didn't check. Here's the 12-point checklist trial lawyers use to lawfully investigate, impeach, and dismantle a medical expert — and where AI now does the heavy lifting.
The 12-Point Checklist
Pull every prior transcript. Their old depo/trial testimony is where they said the opposite. Reading years of it by hand is impossible — AI finds the contradiction in minutes.AI: prior-transcript search
Vet the CV line by line. Board-certification status (current? ever lapsed?), privileges, overstated or retracted credentials, unexplained gaps.
Check for prior Daubert/Frye exclusions. An expert excluded before is gold — often a fast motion in limine.
Run licensure & discipline. State-board actions, sanctions, their own malpractice history.
Calculate the "hired-gun" ratio. Frequency of testimony, % of income from testifying, and whether they're always on one side. (The "40% of my income is testifying" admission wins juries.)
Read their own publications — and use them. Find where the expert's own articles contradict the opinion they're giving in your case.
Attack the methodology, not the conclusion. FRE 702/Daubert: testable? known error rate? peer-reviewed? does it "fit"? Or is it ipse dixit — "true because I say so"?
Build the timeline that makes their story impossible. A Bates-cited chronology exposes exactly where the expert's narrative conflicts with the record.AI: timeline builder
Verify every record citation they make. Especially AI-assisted reports — a surprising share of "cited" findings aren't actually on the page. That's impeachment on a platter (and an ABA Op. 512 problem for their counsel).AI: Bates verification
Lock them down in deposition. Commit → credit → confront. Get the concession in depo; spring the contradiction at trial.
Cross with short leading questions. Control the witness with the chapter method; never ask one question too many; end each chapter on your point.
Catch the live contradiction. The most devastating impeachment is real-time — flag the moment the expert contradicts their report or prior testimony while still under oath.AI: live cross engine
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We're building the AI-Era Cross-Examination Masterclass — the full playbook behind this checklist, for plaintiff and defense. Drop your email for the printable PDF and first access when enrollment opens.
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Steps 1, 8, 9 & 11 above are exactly what our Courtroom AI does — mine prior testimony, build the Bates-cited timeline, verify every citation, and catch contradictions live. It's free to try, no credit card: create a free account.