Two Legal Systems Divided by a Common Language: How UK and US Procedure Shape Strategy and Expert Evidence

• This panel brings together leading litigators and expert witnesses with deep experience in both UK and US procedures. While the UK and US systems share common roots, their procedural frameworks diverge in ways that fundamentally shape litigation and present key strategic considerations on each side of the pond. The panel will share their knowledge of both systems and highlight common pitfalls for unwary lawyers and clients navigating a new forum.

• Rather than simply comparing systems, the discussion will focus on these challenges in the context of expert evidence. Many of the practical realities for disputes across boarders may be crystallised through the lens of the expert’s mandate:

i. Independence, advocacy and perception in different forums

ii. The impact of depositions and joint statements on expert preparation

iii. Admissibility challenges and credibility before judges and juries

iv. How procedural structures influence witness testimony