[Your Name] [Your Address] [City, State, ZIP] [Email Address] [Phone Number] [Date] [Attorney's Name] [Law Firm Name] [Address] [City, State, ZIP] Re: Plaintiff's Amended Designation of Experts Dear [Attorney's Name], I hope this letter finds you well. I am writing to provide you with the Plaintiff's Amended Designation of Experts, as per the request of [Court Name] in the case of [Plaintiff's Name] v. [Defendant's Name]. As we discussed previously, we have reevaluated our expert witness list and have made some amendments to strengthen our case. The designated experts are chosen based on their extensive experience, qualifications, and expertise in their respective fields. 1. [Expert's Name — Field of Expertise]: We have designated [Expert's Name] as an expert witness in the field of [Field of Expertise]. With over [number] years of experience and a stellar track record, [Expert's Name] will provide valuable insights regarding the [specific aspect of the case]. 2. [Expert's Name — Field of Expertise]: Our second designated expert witness is [Expert's Name], specializing in [Field of Expertise]. Having worked on similar cases in the past, [Expert's Name] will offer critical opinions and analysis regarding [specific aspect of the case]. 3. [Expert's Name — Field of Expertise]: Lastly, we have designated [Expert's Name] as an expert witness in the field of [Field of Expertise]. With [number] years in the industry, [Expert's Name] will bring forth crucial evidence and opinions pertaining to [specific aspect of the case]. We believe that the inclusion of these experts will greatly strengthen our case and ensure a fair and just trial. We have provided their detailed curriculum vitae and a summary of their proposed testimony for your perusal, enclosed with this letter. Please acknowledge receipt of this Amended Designation of Experts within [number of days] days from the date of this letter. Additionally, please inform us of your designated experts within the stipulated time frame to maintain transparency and facilitate efficient communication between both parties. Should you require any further information or have any concerns regarding this amendment, kindly contact me at your earliest convenience. We appreciate your cooperation in this matter and look forward to a successful resolution of this case. Thank you for your attention to this matter. Sincerely, [Your Name]
Dallas Texas Sample Letter regarding Plaintiff's Amended Designation of Experts
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FAQ
Rule 190 - Discovery Limitations 190.1 Discovery Control Plan Required. Every case must be governed by a discovery control plan as provided in this Rule. A plaintiff must allege in the first numbered paragraph of the original petition whether discovery is intended to be conducted under Level 1, 2, or 3 of this Rule.
Rule 190.4. Discovery Control Plan - By Order (Level 3) (1999) (a) Application. The court must, on a party's motion, and may, on its own initiative, order that discovery be conducted in accordance with a discovery control plan tailored to the circumstances of the specific suit.
The amendment to Rule 194 replaces requests for disclosures with a mandatory disclosure requirement similar to the disclosure requirement in the Federal Rules of Civil Procedure. Under amended Rule 194, disclosures are due within 30 days after the first answer is filed.
Every case filed in Texas state court requires the plaintiff to choose a discovery plan: Level One, which applies only for cases where the plaintiff seeks less than $100,000 in damages; Level Two, which applies by default to all other cases and has its own specific set of deadlines; and Level Three, which allows the
Under Level 2 discovery, each side is only allowed 25 written interrogatories that ask more than identifying information about a document. Additionally, the responding party may respond by telling the other side where the information can be found in public records instead of answering the question directly.
(d) Draft Expert Reports and Disclosures Protected. A draft expert report or draft disclosure required under this rule is protected from discovery, regardless of the form in which the draft is recorded.
(3) Interrogatories. Any party may serve on any other party no more than 25 written interrogatories, excluding interrogatories asking a party only to identify or authenticate specific documents. Each discrete subpart of an interrogatory is considered a separate interrogatory.
Texas collection lawyers are always aware of applicable case law regarding experts, retained and non-retained expert witness that will testify at trial. A retained expert is obviously retained by, employed by, or otherwise subject to the control of the party.
Expert witness are protected from disclosure, regardless of the form of the communications. However, the protection applies to all other aspects of the communication beyond the excepted topics.
Ordinarily, communications between a lawyer and a testifying expert are discoverable under Texas Rule of Civil Procedure 192.3(e).
