The sequestration of expert witnesses falls under Hawaii’s Rules of Evidence, Rule 615. HAW. REV. STAT. ANN. § 626-1 (West 2017). This rule requires the court to exclude a witness from the courtroom as to not hear testimony of other witnesses when a party requests or through an order of its own. Id. There are three exceptions of individuals that cannot be excluded and expert witnesses fall under the third exception. Id. The third exception is for “a person whose presence is shown by a party to be essential to the presentation of the party’s cause.” Id. The trial judge maintains discretion as to whether to exclude an expert witness based on the witness’s essentiality. State v. Culkin, 35 P.3d 233 (Haw. 2001).
