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By an expert not retained or specially employed by any party in anticipation of litigation or preparation for trial as described by Civ. R.26 B) (4), if the fact or opinion does not describe specific events or occurrences in dispute and results from study by that expert that was not made at the request of any party. (d) Subjects a person to undue burden. (4) Before filing a motion pursuant to Division (3) (d) of this rule, a person resisting discovery under this rule shall attempt to resolve.

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