Jeff Balcombe, CPA speaking at the SEAK National Expert Witness Conference gave attendees the following practical tips on expert witness report writing:

  • Stay within your area of expertise
  • Proactively address all key facts, including ones that are contrary to or mitigate your conclusions
  • Don’t be like Sgt. Schultz of Hogan’s Heroes: “I hear nothing, I see nothing, I know nothing!”
  • Simplify your writing
  • Keep your opinions organized and digestible using topic headings and “bite-sized” paragraphs
  • Beware of using of legal or other terms of art
  • Grammar
    • Use first person
    • Avoid passive tense
  • Confident does not mean arrogant. Be professional and objective
  • Avoid exaggerated terms (e.g., grossly, seriously, unconscionable, fallacious, specious, etc.)
  • Don’t be flashy like Apollo Creed in Rocky IV
  • Resist the URGE

For additional expert witness report writing tips, see the new text How to Write an Expert Witness Report