Communications with your Expert: Overcoming Discovery Hurdles
By Kluger, Kaplan, Silverman, Katzen & Levine, P.L. November 1, 2012
By Alan J. Kluger It is standard practice in Florida (and most jurisdictions) to issue a subpoena duces tecum when deposing an opponent’s expert witness, in order to obtain the documents that the expert relied upon in forming his or her opinion. Florida’s Rules of Civil Procedure permit a …