Deposition Questions
(Employment Discrimination Class Action) (Defendant to Plaintiffs' Expert Witness)

This deposition outline and set of deposition questions provide sample questions directed to a plaintiffs' expert in an employment discrimination class action. This form contains practical guidance, drafting notes, and alternate and optional clauses. This deposition outline is intended for private employers. It is based on federal law and does not address all potential state law distinctions; thus, you should check any relevant state and local laws. For guidance on litigating all phases of employment discrimination class actions, including depositions, see Employment Discrimination Class and Collective Actions: Special Issues and Considerations. For additional information on employment discrimination litigation and class actions, see Employment Litigation – Discrimination, Harassment, and Retaliation task page and Employment Litigation – Class and Collection Actions task page. For information on state laws governing discrimination and retaliation claims, see Discrimination, Harassment, and Retaliation State Practice Notes Chart and Discrimination, Harassment, and Retaliation State Expert Forms and Checklists Chart.