Having worked as an independent fee appraiser for several attorneys on civil suits, bankruptcy, divorce and condemnation cases, I have found that my best results as an expert witness have always come from following some basic assignment preparation and archival rules.

I always begin a litigation assignment by creating a new binder with a printed title like “John Doe vs. XYZ Enterprises – Appraiser Work File.”  If you want to enhance it with a professional logo, letterhead or graphics, that’s a plus.

I place any and all correspondence, engagement letters, instructions, plans, drawings, complaints, supplied definitions, supplied case law and related pre-appraisal documents in the “assignment info” section of the binder.

The next section in the binder holds background information that I summarized in my written regional, market and sub-market discussion.  If the information is taken from State University reports, U.S. Census data, the State Demographer or other sources, I include the documents in my work file binder for future reference.

Usually I include at least the following sections in the binder; assignment info, market area documents, cost approach, sales approach, income approach, market research, client supplied data, news / articles, miscellaneous and my report.  Of course their can be several other categories that you may want to include that are specific to your property or your assignment.

I populate the binder within the sections that I have labeled.  In the sales approach section, I include a map of comparable sales, the printed pages that detailed the sales information, a list of sales that were displayed and excluded from consideration during the appraisal process.

In the income approach section I include printed source pages that display the current interest rates, capitalization rate studies, income and expense information on similar properties,

Cost approach pages include the printed pages referenced from Marshall & Swift together with all of the multiplier pages and depreciation page if that was used as the basis for depreciation.  

It is important to keep a journal with names, dates, times, phone numbers and discussion summaries for all of the individuals who confirmed sales or who provided other pertinent information.  There is nothing worse than having to admit in the deposition or at trial that you had a source who provided important information, but you don’t remember who that was.

News articles, professional (trade) articles and reference materials that you reviewed during the appraisal process and that you relied upon is important to include in your binder.  Make sure that you know where this information came from, even if you only include the Internet URL or Journal details.   

While some appraisers make a contrary argument that you should accumulated as little related to the assignment as possible in your work file, so that the opposition’s attorney will have less information to attack you about, I prefer the “include everything relied upon in the work file” approach.