This form is a sample letter in Word format covering the subject matter of the title of the form.
Subject: Request for Amendment of Plaintiff's Designation of Experts [Case Name/Number] [Your Name] [Your Address] [City, State, ZIP] [Date] [Opposing Counsel's Name] [Opposing Counsel's Law Firm] [Address] [City, State, ZIP] Re: [Case Name/Number] Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing in relation to the above-mentioned case, specifically concerning the Plaintiff's recent Amended Designation of Experts filed on [Date of Filing] in accordance with New Mexico Rules of Civil Procedure [Applicable Rule Number]. Firstly, we acknowledge the Plaintiff's right to amend their designation of experts under the aforementioned procedural rule. However, after thoroughly reviewing the amended experts designated by the Plaintiff, our legal team has identified discrepancies and potential concerns pertaining to the relevancy, qualification, and potential bias of the designated experts. Our main purpose in reaching out is to address these concerns and hopefully encourage a resolution that ensures the fair presentation of expert testimony during the proceedings. We believe that by addressing these concerns promptly and rectifying any potential issues related to expert testimony, we can avoid any unnecessary delays or disputes that may hinder the resolution of this case. Given the circumstances, we respectfully request that the Plaintiff reconsider their Amended Designation of Experts and provide the following information for each designated expert: 1. Expert's Name and Professional Background: Kindly provide a comprehensive summary of each expert's education, training, professional affiliations, and any relevant experience in relation to the issues at hand in this case. 2. Area of Expertise: We require a clear statement specifying the area of expertise for which each expert is designated. Please ensure that their designated field of expertise aligns with the relevant issues raised in this case. 3. Expert's Opinions: To facilitate an efficient exchange of information, we kindly request a detailed outline of the specific opinions, findings, and conclusions that each expert intends to present at trial or in any expert reports. 4. Expert's Qualifications: We would appreciate receiving copies of the expert's curriculum vitae, including a list of any articles, publications, or presentations relevant to their area of expertise, as well as any previous expert testimony they have provided in other cases within the last five years. 5. Evidence of Potential Bias: It is crucial to ensure that the designated experts remain unbiased and impartial throughout the proceedings. Therefore, we request any information indicating potential bias or conflict of interest, such as financial relationships or connections to parties involved in this case. We understand the complexities of expert designations and the importance of fully disclosing the qualifications and opinions of designated experts. Our objective is to promote a fair and just resolution to this case by ensuring that each expert's testimony is reliable, relevant, and free from any potential flaws or biases. We kindly request that you address the concerns raised above within [provide a reasonable deadline to respond, typically two weeks from the date of the letter]. If necessary, we are open to engaging in a meet-and-confer conference to discuss any potential issues and reach a mutually beneficial resolution. Thank you for your attention to this matter. We look forward to your prompt response and cooperation, which will allow us to proceed with the discovery process smoothly and efficiently. Sincerely, [Your Name] [Your Law Firm, if applicable] [Phone Number] [Email Address]
Subject: Request for Amendment of Plaintiff's Designation of Experts [Case Name/Number] [Your Name] [Your Address] [City, State, ZIP] [Date] [Opposing Counsel's Name] [Opposing Counsel's Law Firm] [Address] [City, State, ZIP] Re: [Case Name/Number] Dear [Opposing Counsel's Name], I hope this letter finds you well. I am writing in relation to the above-mentioned case, specifically concerning the Plaintiff's recent Amended Designation of Experts filed on [Date of Filing] in accordance with New Mexico Rules of Civil Procedure [Applicable Rule Number]. Firstly, we acknowledge the Plaintiff's right to amend their designation of experts under the aforementioned procedural rule. However, after thoroughly reviewing the amended experts designated by the Plaintiff, our legal team has identified discrepancies and potential concerns pertaining to the relevancy, qualification, and potential bias of the designated experts. Our main purpose in reaching out is to address these concerns and hopefully encourage a resolution that ensures the fair presentation of expert testimony during the proceedings. We believe that by addressing these concerns promptly and rectifying any potential issues related to expert testimony, we can avoid any unnecessary delays or disputes that may hinder the resolution of this case. Given the circumstances, we respectfully request that the Plaintiff reconsider their Amended Designation of Experts and provide the following information for each designated expert: 1. Expert's Name and Professional Background: Kindly provide a comprehensive summary of each expert's education, training, professional affiliations, and any relevant experience in relation to the issues at hand in this case. 2. Area of Expertise: We require a clear statement specifying the area of expertise for which each expert is designated. Please ensure that their designated field of expertise aligns with the relevant issues raised in this case. 3. Expert's Opinions: To facilitate an efficient exchange of information, we kindly request a detailed outline of the specific opinions, findings, and conclusions that each expert intends to present at trial or in any expert reports. 4. Expert's Qualifications: We would appreciate receiving copies of the expert's curriculum vitae, including a list of any articles, publications, or presentations relevant to their area of expertise, as well as any previous expert testimony they have provided in other cases within the last five years. 5. Evidence of Potential Bias: It is crucial to ensure that the designated experts remain unbiased and impartial throughout the proceedings. Therefore, we request any information indicating potential bias or conflict of interest, such as financial relationships or connections to parties involved in this case. We understand the complexities of expert designations and the importance of fully disclosing the qualifications and opinions of designated experts. Our objective is to promote a fair and just resolution to this case by ensuring that each expert's testimony is reliable, relevant, and free from any potential flaws or biases. We kindly request that you address the concerns raised above within [provide a reasonable deadline to respond, typically two weeks from the date of the letter]. If necessary, we are open to engaging in a meet-and-confer conference to discuss any potential issues and reach a mutually beneficial resolution. Thank you for your attention to this matter. We look forward to your prompt response and cooperation, which will allow us to proceed with the discovery process smoothly and efficiently. Sincerely, [Your Name] [Your Law Firm, if applicable] [Phone Number] [Email Address]