Construction workmanship expert witness services, nationwide from Chicago773-619-1226 | paul@expertwitness.co

Reports, Deposition and Trial

Construction Expert Witness Testimony and Reports

Construction expert witness testimony is the point where every earlier step is tested. Paul Gaston prepares written reports that state each opinion, its basis and the supporting exhibits, then explains the work in plain terms at deposition, arbitration and trial. He has testified at deposition and trial in Illinois, at an AAA arbitration hearing, and at deposition in Wyoming.

What Goes Into a Workmanship Report

A report has to be clear enough for a juror and detailed enough for opposing counsel. Paul's reports typically include:

  • A description of the assignment and the materials reviewed
  • A summary of his qualifications, with his CV attached
  • A description of the inspection and the conditions observed
  • The requirements each condition is compared with, by source
  • Each opinion, stated plainly, followed by its basis
  • Photographs and exhibits keyed to the opinions
  • Where requested, the corrective scope and cost of repair

Reports are prepared to meet the disclosure requirements counsel identifies for the forum.

Opinions Built to Be Tested

Every opinion should survive the question "how do you know that?" Paul ties each opinion to a document, an observation or both, and he identifies the professional experience that supports it. He also states the limits of each opinion. An expert who claims too much invites a challenge to everything he says; an expert who stays within his experience is more credible on the points that matter.

The methodology behind these opinions is described on the workmanship analysis page.

Deposition

At deposition, opposing counsel tests the qualifications, the method, the basis and the limits of each opinion. Paul prepares by reviewing his file and report, and he answers questions directly. If he does not know something or did not review something, he says so. That candor tends to strengthen the opinions he does hold.

Arbitration and Trial

At a hearing or trial, the audience changes. Paul explains construction in practical terms, using photographs and exhibits to show the fact finder what he saw and why it matters. His experience directing crews and explaining work to owners and inspectors helps him communicate technical points without jargon. His testimony history appears in his CV.

Preparing With Counsel

Before deposition or trial, Paul meets with retaining counsel to review the report, the exhibits and the issues likely to be raised. He identifies any new documents or testimony that bear on his opinions so that counsel can address them in time. Preparation sessions are focused on explaining the work clearly; the opinions themselves remain his own and follow the evidence. If new information changes an opinion, Paul tells counsel promptly and explains why, because an expert who adjusts to the evidence is more credible than one who defends a position the record no longer supports.

Questions

Common Questions

What does Paul's expert report include?

The materials reviewed, his qualifications, the inspection, the requirements used, each opinion with its basis, keyed photographs and exhibits, and where requested a repair scope and cost.

Where has Paul given testimony?

He has testified at deposition and trial in a Will County, Illinois construction defect case, along with an AAA arbitration hearing and other depositions.

Can Paul prepare a rebuttal report?

Yes. He reviews the opposing report and addresses each opinion, explaining where the documents and field conditions support or contradict it.

How does Paul handle questions outside his expertise?

He says so. Staying within his experience as a contractor and carpenter protects the credibility of the opinions he does give.

Have a workmanship dispute that needs a builder's eye?

Send the party names for a conflict check and a short description. Paul will tell you plainly whether the matter fits his experience.