I, __________ [attorney for party designating expert], declare:
1. I am an attorney licensed to practice law in
California. I am the attorney of record for __________
[designating party], the __________ [plaintiff or defendant] in
the above cause of action.
2. I make this declaration pursuant to section 2034(f)(2)
of the Code of Civil Procedure. On behalf of __________
[designating party], I submitted a list of expert witnesses on
whom I expect to rely at trial pursuant to section 2034(f) of
the Code of Civil Procedure.
3. The list includes __________ [name of expert], who is
__________ [a party or an employee of a party or an expert
retained in preparation for trial or an expert retained to form
and express opinions in anticipation of litigation] as described
in section 2034(a)(2) of the Code of Civil Procedure.
4. __________ [Expert's] qualifications are as follows:
__________ [briefly list expert's qualifications].
5. __________ [Expert] is expected to testify that
__________ [briefly summarize substance of expected testimony
6. __________ [Expert] has agreed to testify at the trial
of this action.
7. __________ [Expert] will be sufficiently familiar with
this action to permit other parties to depose __________
[expert] in a meaningful way concerning the testimony _____ [he
or she] is expected to give at trial.
8. __________ [Expert's] customary hourly fee for
providing deposition testimony is $__________. __________
[Expert's] customary daily fee for providing deposition
testimony is $ __________.
I declare under penalty of perjury under the laws of the
State of California that the foregoing is true and correct.