An expert retained in mass tort litigation may be required to focus on multiple cases consolidated for discovery and trial, involving thousands of pages of medical records, deposition transcripts, and other discovery material. Expert opinions in mass tort litigation must address both case-specific and generic issues. A statement that is innocuous in one case may be harmful when applied to another. Taken together with the technical sophistication of the issues involved in each case, these issues necessitate a measured approach for dealing with experts.

The following tips are provided to assist the practitioner in handling and preparing expert witnesses in mass tort litigation. We discuss how to organize thousands of pages of discovery material provided to experts, prepare experts for deposition and trial, and form a team responsible for these tasks. Although the tips focus on experts in mass tort cases, they apply equally to other types of litigation involving multiple-party complex cases.