_______ by counsel of record, _______, submits the following Interrogatories to ________to be answered concerning that party's expert witness, pursuant to Rules 26(b)(4) and 34, of the Federal Rules of Civil Procedure, which are to be answered separately and fully in writing, under oath, within thirty (30) days after service. Answers must be updated as additional responses become available. 

1. Identify each person assisting in answering this discovery and denote which questions are answered by which person.
2. State the names, addresses and occupations of such persons. 
3. State all areas of specialization of the expert's occupation or profession. 
4. Describe all professional or social relationships the experts have with _______ at the present and at any time in the past. 5
5. State when the experts were hired and by whom. Attach copies of all correspondence or notes of telephone conversations between experts and the hiring party or counsel. 
6. What relationships of a social or professional nature do the experts have with ______'s counsel? Have the experts ever been engaged as an expert or testified for ______'s counsel previously? If so, provide all details of each testimonial or forensic engagement. 
7. What is the expert's formal education and employment experience in detail? Attach a current curriculum vitae or detailed resume. 
8. What is the expert's agreement for compensation with the hiring party? Include all amounts paid or to be paid and attach copies of the engagement agreements, billing and timekeeping sheets. 
9. State the exact manner in which the expert became familiar with the facts of this case. Detail each and every one of the expert's efforts and include the time devoted to each step. 
10. What was the expert's specific assignment? Describe each and every action taken in completing such assignment. 
11. What is the subject matter of the expert's prospective testimony in the case? How was that assignment given? Produce all documentation of that assignment. Produce all of the expert's files with regard to assignments as they now exist, in original form, without addition or subtraction, and in the original file folders. If material is in computer storage, print it out and produce the printout. 
12. Provide copies of all documents obtained or generated in the course of employment as an expert in this case including, but not limited to: 
    1. All notes made of conversations with other witnesses, parties, other experts, or attorneys for the hiring party;
    2. All reports or writings examined in arriving at the expert's opinion; 
    3. All correspondence with the hiring party and their counsel;
    4. Any other documentation generated in arriving at conclusions;
    5. All investigative reports obtained that were prepared by others, or generated by the expert; 
    6. Any photographs, recordings, drawings of calculations prepared as part of the expert's study; 
    7. Any documents which the expert located, specifying the source of such documents. 
13. How much time has the expert spent on this project? Allocate such time to each particular task performed. 
14. Give the name, address, and telephone number of any attorney, witness, party or other expert with whom the expert has conferred about this assignment. Detail the response or information obtained from any such person.
15. State what experience the expert has had with similar or comparable projects. What prior expert testimony or reports has the expert ever prepared or given concerning a project similar to that of this case.
16. State whether any field investigation was performed. Give the name, address and telephone number of any person with whom the expert met during such field investigation. Detail the time devoted to such effort. 
17. Provide a bibliography of all documents, books, publications, treatises, or any other written material upon which the expert relied in forming opinions. Be page specific. 
18. Provide a bibliography of all documents, books, publications, treatises, or any other written material considered by the expert to be authoritative on the subject matter of projected testimony. 
19. State the facts, opinions and conclusions to which the expert intends to testify at a trial or hearing in this case. 
20. What other additional specific opinions and conclusions did the expert reach concerning this project?
21. Give a summary of the technical, factual, professional, or scientific basis and ground for each opinion reached by the expert to support each conclusion or opinion. 
22. State the expert's reasoning by which each conclusion or opinion (in paragraphs 19 and 20) is supported or reached, based on the information in paragraph 21 above, or otherwise. 
23. What additional assignments has the expert been given which have not yet been completed? 
24. What additional work do you believe will be necessary for the expert to complete prior to trial or hearing?
25. When is the expert expected to complete such assignments? 

These are continuing interrogatories and requests for production. Experts must supplement their responses in a prompt and timely fashion.