Sanchez Expert Checklist: Preparing an Expert Witness for a California Trial

By David Gammill · Last reviewed: September 20, 2026

The Sanchez Expert Checklist is a two-page working document for California attorneys preparing an expert witness for trial. It walks the basis of each opinion through the two questions that decide almost every objection under People v. Sanchez (2016) 63 Cal.4th 665: is the information case-specific, and is the expert relating it as true? Enter your name and email below and the checklist is yours.

What’s Inside

• Before disclosure: sorting every item the expert relied on into background and case-specific, and writing the route in for each case-specific item.
• Medical records: the Evidence Code section 1561 custodian declaration, the section 1271 motion, and what happens without them.
• Treating physicians and the collision report: which opinions come in as percipient testimony, and why nothing from the report comes in as true.
• Dependent experts: the order of witnesses for the life care planner and the economist.
• At trial: the objection, the motion to strike, the section 803 ruling, and the “both ways” question to ask the judge.

Every case and statute on the checklist is cited, and the reasoning behind each item is set out in our explainer, When Is Hearsay Admissible in Expert Witness Testimony?

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Disclaimer: The checklist is a working document for attorneys, educational and informational in nature. It does not constitute legal advice for any specific case, and downloading it does not create an attorney-client relationship. Every case turns on its own facts. This page is attorney advertising.