3) Consult with opposing counsel in the scheduling of appearances, meet- ings and depositions. And provided to opposing counsel.The report of an expert must disclose a complete statement of all opinions and the basis and reasons for them as to. Durst Kerridge is an Ohio litigation boutique representing clients from around the world in high-stakes commercial and complex civil litigation matters. Law Offices, P.C., specializes in the fields of personal injury, medical and legal malpractice, and police brutality. What's a nice way to ask opposing counsel to consent to changing a hearing date after they opposed to it being untimely? Up to 30 days will be granted without approval of opposing counsel. My favorite is a story from Gerry Spence. For those who don't know, he is a famous trial attorney. {¶23} Counsel must provide a list of proposed witnesses to opposing counsel, even in the absence of a discovery request to do so.