Plaintiff's Interrogatories to Defendants re Experts and Witnesses

Plaintiff’s Interrogatories to Defendants Regarding Experts and Witnesses Relative to Defendants’ Witness List Dated ______________

NOW COMES Plaintiff, __________, by and through counsel, ____________, and requests that the following Interrogatories, submitted under [Rule], be answered by Defendanst, under oath and that the answers be served upon the undersigned attorney for Plaintiff within twenty eight (28) days.

1. As to each and every expert, who may render expert testimony, state:

   1. Their name and address;

   2. Whether the expert witness is in any way related to the Defendants and/or their attorney;

   3. The education background of the expert witness and include the following as to each individual:

1. Name and address of college or university including any postgraduate education;

2. Dates of attendance of each;

3. Nature and scope of education received;

4. Whether or not any of the above schools were accredited;

5. Training in any specialty;

6. Degrees received;

   1. Dates each degree was received;

   2. Any honors received.

7. If said expert did not graduate from any educational facility he/she attended, please state:

   (a) Reason for failure to graduate;

   (b) Amount of required program not completed.

   (c) The prior work experience of each expert, and for each one include:

1. Employers for the past ten (10) years;

2. Title or positions held;

3. Duties and responsibilities;

4. Special training or experience;

5. Any other experience which said expert will rely upon in formulating any opinion relative to this litigation.

   5. Any publications authored by said expert, and as to each such publication by each individual, state:

1. Title;

2. Publishers;

3. Date of publication;

4. Content and subject;

5. Whether any of the above described publications will be relied on by each expert in formulating their opinions in this litigation. If so, which expert and which publication?

   6. If any expert has ever testified as an expert witness in the past, for each time, please state:

1. Number of court appearances in the last ten (10) years;

2. Number of consultations involving legal actions in the last ten (10) years;

3. Name of each case, court and party by whom they were called or consulted;

4. Date of each appearance in court;

5. Subject matter of testimony or expertise in each case;

6. Subject matter of each case;

7. Whether each expert was, in prior cases, either:

   (a) Challenged;

   (b) Denied.

   7. The number of times each expert witness has appeared for a deposition in the last...