Form of motion

Plaintiffs move, pursuant to Federal Rule of Civil Procedure 37(c)(1), for an order precluding defendants from offering the testimony of Professor Horace Brown, the expert designated by defendant, on the ground that the disclosure required by Rule 26 [or appropriate state statute] fails to provide a complete statement of all opinions to be expressed at trial and the basis for such opinion beyond that contained in his expert report filed pursuant to Rule 26(a)(2)(B).

In addition, plaintiffs move to preclude the defendants’ use of any exhibits other than those attached to Professor Brown’s...