CPLR 3101(d) dictates the parameters of the crucial expert disclosure required in civil litigation to prevent unfair surprise at trial. It provides that a party disclose in reasonable detail an expert’s qualifications, the facts and opinions on which the expert is expected to testify at trial and the grounds for this testimony. The statute states in pertinent part:
(d) Trial preparation. 1. Experts. (I) Upon request, each party shall identify each person whom the party expects to call as an expert witness at trial and shall disclose in reasonable detail the subject matter on which each expert is expected to testify, the substance of the facts and opinions on which each expert is expected to testify, the qualifications of each expert witness and a summary of the grounds for each expert’s opinion…
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