Identification Of The Expert, State And Your Place And Date Of Birth
2. Identify each person having discoverable information that tends to support a position that you have taken or intend to take in this action, and state the subject matter of the information possessed by that person.
3. Identify each person whom you expect to call as an expert witness at trial, state the subject matter on which the expert is expected to testify, state the substance of the findings and opinion to which the expert is expected to testify and a summary of the grounds for each opinion, and, with respect to an expert whose findings and opinions were acquired in anticipation of litigation or for trial, summarize the qualification of the expert, state the terms of the expert’s compensation, and attach to your answers any available list of publications written by the expert and any written report made by the expert concerning the expert’s findings and opinions.
4. If you intend to rely on any documents, electronically stored information, or tangible things to support a position that you have taken or intend to take in the action, including any claim for damages, provide descriptions, by category and location, of all such documents, electronically stored…