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Chapter 5

Form 5-19

For required initial disclosures, see form 5-18. For required pretrial disclosures, see form 5-20.

No objections or assertions of work product are allowed to a rule 194 disclosure. Tex. R. Civ. P. 194.5. However, a party may assert any applicable privileges other than work product.

Include the following notice if a minor is named in the caption or if the response contains other unredacted sensitive data. See § 6 of the Introduction in volume 1 of this manual concerning protection of sensitive data in filed documents.

NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA

[Caption. See § 3 of the Introduction in volume 1 of this manual.]

[Petitioner/Respondent]’s Required Testifying Expert Disclosures

[Name], [attorney for Petitioner/attorney for Respondent/Petitioner/Respondent], pro­vides the attached testifying expert disclosures required under rules 194 and 195.

The disclosures must be signed as required by Tex. R. Civ. P. 191.3.

   
[Name]
Attorney for [Petitioner/Respondent]
State Bar No.:
[Email address]
[Address]
[Telephone]
[Fax]

For certificate of service, see form 21-11.

Required Testifying Expert Disclosures

1.The name, address, and telephone number of each testifying expert.

RESPONSE:

2.The subject matter on which each testifying expert will testify.

RESPONSE:

3.The general substance of each testifying expert’s mental impressions and opinions and a brief summary of the basis for them or, if the expert is not retained by, employed by, or otherwise subject to the control of [Petitioner/Respondent], documents reflecting such infor­mation.

RESPONSE:

4.For each testifying expert retained by, employed by, or otherwise subject to the control of [Petitioner/Respondent], all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of the expert’s testimony.

RESPONSE:

5.For each testifying expert retained by, employed by, or otherwise subject to the control of [Petitioner/Respondent], the expert’s current resume and bibliography.

RESPONSE:

6.For each testifying expert retained by, employed by, or otherwise subject to the control of [Petitioner/Respondent], the expert’s qualifications, including a list of all publica­tions authored in the previous ten years.

RESPONSE:

7.For each testifying expert retained by, employed by, or otherwise subject to the control of [Petitioner/Respondent], other than an expert who is the attorney of [Petitioner/Respondent] who is testifying to attorney’s fees, a list of all other cases in which, during the previous four years, the expert testified as an expert at trial or by deposition.

RESPONSE:

8.For each testifying expert retained by, employed by, or otherwise subject to the control of [Petitioner/Respondent], a statement of the compensation to be paid for the expert’s study and testimony in the case.

RESPONSE: