How to help your economic expert deal with 'impeachment nuggets'

In an interesting article posted on, The Illinois Trial Practice Weblog, the author discussed how to ask questions at a deposition that can be used to impeach a witness if they change their story at trial. The weblog said:

...An impeachment nugget is a question and answer in a deposition about a single fact, which can be easily used at trial to impeach a witness who tries to change his story. A very simple example:

Q. The light was green, correct?

A. Yes....

How can you help your economic expert deal with these types of questions?

Answer: Make sure that she or he is telling the whole truth on the first go round!

This may be simple advice, but it can not be stressed enough. Provide them with enough information to make a complete and accurate economic assessment as early as possible. It also helps to make the economic expert feel comfortable that there are 'no secrets' and everything has been disclosed fully to the opposing counsel.