Preparing for Deposition for Traumatic Brain Injury Cases
Preparing a vocational or life care planning expert for deposition in a TBI case focuses on the neuropsychological integration, severity classification, and the methodology used to translate cognitive findings into vocational or care projections.
Checklist
- Review the expert report end-to-end
- Confirm all source citations and file materials
- Prepare the expert on contested severity classification
- Review opposing expert's report for anticipated lines
- Rehearse explanation of neuropsychological-to-vocational translation
Questions to ask the expert
- What severity classifications did you consider and why?
- How did you apply neuropsychological findings to earning capacity?
- How did you address pre-existing conditions?
Timeline
2-3 preparation sessions recommended prior to deposition.
Required documents
- Expert's full file
- Neuropsychological reports
- Opposing expert's report
Common pitfalls
- Overreaching on severity
- Weak documentation of peer-reviewed worklife adjustments
Frequently Asked Questions
Should the expert bring the full file to deposition?
Yes, consistent with jurisdictional subpoena requirements.
References
Ready to Get Started on traumatic brain injury cases?
Contact KWVRS to discuss scope, timing, and the deliverables appropriate to the matter. Plaintiff and defense.