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Expert Witness Declarations This disclosure needs to contain: "(1) A brief narrative statement of the qualifications of each expert. (2) A brief narrative statement of the general substance of the testimony that the expert is expected to give.(A) Deposition of an Expert Who May Testify. A party may depose any person who has been identified as an expert whose opinions may be presented at trial. The report must include "a complete statement of all opinions the witness will express and the basis and reasons for them. (2) Disclosure of Expert Testimony. Each party must disclose information about all experts whose testimony will be used at trial. Discovery about and from a testifying expert may only be obtained through a Rule. Discovery about and from a testifying expert may only be obtained through a Rule. As a practical matter, it is the rare construction case that does not require disclosure of experts before trial.