© D.L. Crumbley
Motions To Exclude Expert Testimony
1. Daubert challenges.
2. Frye challenges.
3. Does not qualify as an expert by knowledge, skill, experience, training, or education.
4. Requires a valid connection to the pertinent inquiry as a precondition to admission.
5. Courts remain vigilant against the admission of legal conclusions.
6. In re Paoli Railroad Yard PCB Litigation, 35 F.3d 717 (3rd Cir. 1994) lists others.
a. Relationships of technique to methods already established to be reliable.
b. Existence and maintenance of standards controlling technique’s operation.
c. Expert witness’ qualifications and non-judicial uses to which method has been put.
7. Side-taking or result –oriented work.
8. Conflict of interest.
9. Ghost-written report.
11. Name not disclosed within time limit.
12. Improper expert witness designation.