For Property Insurance Attorneys
The 12 questions the carrier's expert will ask your estimator in deposition— and how to prepare.
A practical audit of the 12 deposition questions that expose methodology gaps in property damage estimates, mapped to the four Daubert prongs carriers use to exclude expert testimony.
Get the guide.
Delivered to your inbox in 60 seconds.
The pattern
After SB-2A, every weakness is a margin hit.
SB-2A changed the economics of Florida first-party property litigation. Fee caps mean every hour your expert spends in deposition defending methodology is an hour that comes out of your margin, not the carrier's. The carrier's counsel knows this. Their strategy is no longer just to reduce the claim — it's to make the expert expensive to defend.
The 12 questions in this guide are the ones carrier experts and defense counsel ask repeatedly in deposition. They map directly to the four Daubert prongs: testability, peer review, known error rate, and general acceptance. If your estimator can't answer them cleanly, opposing counsel doesn't need to win on the merits — they win on the cost of your expert's preparation.
These 12 questions map to the four Daubert prongs carriers use to challenge expert testimony. This guide shows you where the exposure is — and how to close it before deposition.
What's inside
The 12 questions, organized by Daubert exposure
- ✓4 methodology questions that test whether your estimator can articulate a repeatable, testable process under cross-examination
- ✓4 documentation questions that probe whether the estimate file contains the peer-reviewable evidence Daubert requires
- ✓4 qualification questions that challenge credentials, training currency, and scope-of-opinion boundaries
- ✓Each question includes the Daubert prong it targets, the carrier's strategy behind it, and the documentation that closes the gap
- ✓A pre-deposition audit checklist you can run against any estimate file before your expert sits
- ✓Red-flag indicators that tell you when an estimate won't survive a Daubert challenge — before you file the motion
WorldClass Estimates
12 Questions the Carrier's Expert Will Ask in Deposition
— and How to Prepare
worldclassestimates.com · 12 pages
How to use it
Three ways to put it to work this week.
Estimator audit
Before retaining any estimator, run the 12 questions against their file. If the documentation doesn't answer them, the deposition will expose the gaps.
Day-before prep
The night before your expert sits, walk the 12 questions in order. Each one maps to a Daubert prong — if any answer is soft, you know exactly where opposing counsel will push.
Retention screen
Use the red-flag indicators as a quick screen when evaluating whether to retain a new estimating firm. The questions reveal methodology depth faster than a credentials list.
From WCE's track record
5+ years. 20,000+ estimates. Deposition-ready.
The 12 questions in this guide are not hypothetical. They are the questions our estimators have faced in deposition — and the documentation patterns we build into every named estimate so the answers are already in the file before your expert sits.
20K+
Xactimate estimates delivered
Internal case log, WCE
5+
Years writing for Florida attorneys
Operating since founding
Same
Estimator who writes, signs, and deposes
Named estimate modality
Why this matters now
SB-2A made expert costs a contingency line item.
Under SB-2A, attorney fee recovery on first-party property claims is capped. That means every dollar you spend preparing and defending your expert comes out of your contingency — not the carrier's pocket. Carriers know this, and their litigation strategy has shifted accordingly: make the expert expensive to defend, and the case economics collapse.
The 12 questions in this guide are the pressure points carrier counsel targets. If your estimator's file already answers them, deposition prep drops from days to hours. If it doesn't, you'll find out here — not in the deposition room.
About WCE
Built for Florida claims.
WorldClass Estimates writes Xactimate estimates for Public Adjusters, attorneys, and restoration companies. Two modalities: white-label ghost estimates you defend yourself, and named estimates with on-site inspection that we sign and stand behind in deposition. Florida on-site only. Remote across all 50 states. Bilingual EN/ES — every estimator, every report, every call. Xactimate Level 3, IICRC, NORMI, FAA Part 107, and InterNACHI certified.
Common questions
Before you download.
Is this legal advice?
No. This guide covers estimator methodology and documentation — the technical side of the estimate file. It does not provide legal strategy, case evaluation, or litigation advice. Consult your own counsel for legal questions.
Will I get spam?
No. We send roughly one email per month with a new guide or a Florida-specific note. Unsubscribe is a single click and works the first time.
Does this apply outside Florida?
The 12 deposition questions apply in any Daubert jurisdiction. The SB-2A economic analysis is Florida-specific, but the methodology audit works wherever expert testimony is challenged under Daubert or Frye.
Do I need to be a current WCE client?
No. The guide is for any property insurance attorney. If after reading it you want WCE to write a named estimate for a specific case, you can reach out — but the guide stands on its own.
What's the difference between Ghost and Named estimates?
Ghost estimates are white-label — we write the scope, you or your PA's estimator defends it. Named estimates include on-site inspection; our estimator signs the report and sits for deposition. This guide is most relevant to the Named modality, but the documentation patterns apply to both.
If you have a case heading to deposition and want to know whether your estimate file will hold up, schedule a Strategy Session. Julio will review the file and tell you where the gaps are — no commitment, no pitch.
Get the guide.
12 pages. Free. Delivered to your inbox in 60 seconds.