Party making demand: __________ [Name]
To all parties who have appeared in this action and their
attorneys of record:
Pursuant to section 2034 of the Code of Civil Procedure,
__________ [name of demanding party], the __________ [plaintiff
or defendant] in the above cause, demands that all parties to
this action exchange the following information regarding the
expert witnesses on which they intend to rely at trial:
__________ [List information demanded, for example:
1. The names and addresses of any persons, including
parties, whose live or deposition testimony in the form of
expert witness opinion each party intends to introduce into
evidence at trial, or a written statement that the party does
not presently intend to introduce such testimony.
2. If persons listed are parties, employees of a party, or
experts retained to prepare for trial or to form and express
opinions in anticipation of litigation, an expert witness
declaration pursuant to section 2034(f)(2) of the Code of Civil
Procedure.
3. Any reports and writings made by experts who are
parties, employed of a party, or experts retained to prepare for
trial or to form and express opinions in anticipation of
litigation in preparing their opinions.]
__________ [Demanding party] demands that exchange of the
above information occur on __________ [date], at __________
[time], at __________ [address], __________ [city], __________
County, California.
