RICHARD A. SIMMONS

rsimmons@ws-law.com

Waldron & Schneider

15150 Middlebrook Drive Houston, Texas 77058

(281) 488-4438

www.ws-law.com

(1) with regard to all experts testifying for a party seeking affirmative relief, 90 days before the end of the discovery period;

(2) with regard to all other experts, 60 days before the end of the discovery period.

(1) the expert’s name, address, and telephone number;

(2) the subject matter on which the expert will testify;

(3) the general substance of the 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 the responding party, documents reflecting such information;

(4) if the expert is retained by, employed by, or otherwise subject to the control of the responding party:

(A) 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;

(B) the expert’s current resume and bibliography;

(C) the expert’s qualifications, including a list of all publications authored in the previous 10 years;

(D) except when the expert is the responding party’s attorney and is testifying to attorney 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; and

(E) a statement of the compensation to be paid for the expert’s study and testimony in the case.