Deposition of a defense doctor - in concordance or in cahoots!

The insurance company hires two defense doctors to testify.  They don't examine the patient.  Just read the records and come up with opinions.  A nice way for a couch doctor to earn $750 to $1000 per hour.

I take their depositions one after the other.  Dr. 1 is taken at 2:00 and lasts for an hour.  The next is set to start at 3:30.  So what do you think.  Will Dr. 1 and Dr. 2 try to get their story straight in the 15 minutes between the two depositions.  Read on.

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7   Q    Did you speak with Dr. 1?
8   A    Yes.
9   Q    When?
10   A    Not very long ago.  It must have been after his
11        deposition.  He called me before his deposition, and we
12        talked extremely briefly, and then he called me back
13        for -- I was in my car, actually -- for perhaps eight
14        minutes.
15   Q    So I just took his deposition, and then you talked to
16        him before your deposition in the car.  So what did he
17        have to say?
18   A    Well, I had formed some opinions, and he confirmed, you
19        know, my thoughts, so we seemed to be in concordance, if
20        I understood him correctly.
21   Q    In concordance or in cahoots?
22                     MR. CROWELL:  Object.
23   A    That wasn't necessary, ma'am.
24   Q    (By Ms. Koehler)  How often do you try to talk to
25        somebody after their deposition that is right before
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1        your deposition to make sure that your testimony is the
2        same as theirs?
3   A    Well, the way you asked that question no matter what I
4        answer I'm going to be a crook, so I'm not going to
5        answer your question, because I can't.

Tip for Attorneys:  Ask the defense experts about their conversations not only with defense lawyers, but the other expert witnesses.

Karen Koehlerdeposition