texas testifying expert privilege
Once a case evaluation has occurred, an attorney may then discuss with the client the potential benefits and challenges that may come with protracted litigation. Still, others assist the jury in determining whether a companys decision violated some standard or practice that caused or contributed to a persons injury and whether a companys decisions were either or both negligent and grossly negligent. In so deciding, the court is not bound by evidence rules, except those on privilege. I still talk to Nick to this day. John and Nick are well trained, experienced, smart and most importantly, tenaciously dedicated to their clients' interests. Distinguish between testifying and non-testifying experts. He got up to speed quickly on the facts and determined exactly what we needed to do. Your email address will not be published. R. Evid. Morrow & Sheppard would be my first call for legal assistance. Accept same-day payments for your services. Naturally, the property insurer claimed the documents were protected by the attorney-client privilege. Now my family is set up for life. National Security Advisor Condoleezza Rice has refused to testify publicly before the panel investigating the Sept. 11 attacks. Feb. 15, 2019). New York, NY 10005. Could Dickinson be stretched so far as to allow privileged communications between the clients lawyer and the architect-expert since the owner and the architect have a common interest in the pending litigation? The In re City of Dickinson case reminds us that, while not absolute, the attorney-client privilege provides powerful protections and can be asserted in situations when the materials sought are otherwise subject to disclosure. 2 0 obj Cozen O'Connor var today = new Date(); var yyyy = today.getFullYear();document.write(yyyy + " "); | Attorney Advertising, Copyright var today = new Date(); var yyyy = today.getFullYear();document.write(yyyy + " "); JD Supra, LLC. Expert Discovery Rules Do Not Trump the Attorney-Client Privilege, The Texas Supreme Court clarified that when a client or its employee is designated as a testifying expert, the expert discovery rules2do not trump the attorney-client privilege.3The court affirmed that email communications between the clients lawyer and the clients employee-expert transmitting drafts of the experts affidavit were privileged. The policyholder moved for summary judgment on the issue of causation, essentially alleging that its insurer did not pay all damages caused by Hurricane Ike. Experts are either or both routinely hired and consulted in cases involving personal injury. . Breaking into Expert Witness Work:The Ultimate Guide, Techniques for WritingPersuasive Expert Witness Reports, 7 Must-Haves in YourExpert Witness Resume/CV. It is settled in Texas that the protection afforded by the consulting expert privilege is intended to be only a shield to prevent a litigant from taking undue advantage of his adversarys industry and effort, not a sword to be used to thwart justice or to defeat the salutary objects of discovery. Tom L. Scott, Inc. v. McIlhany, 798 S.W.2d 556, 559 (Tex. It's time to renew your membership and keep access to free CLE, valuable publications and more. I have known Nick Morrow for years and I cannot say enough positive things about him. After the case was remanded, the defendants attempted to depose Dr. Capehart. However, as a general rule, experts relied on for consultation are able to learn facts from the client under the attorney-client privilege. See, e.g., In re Pioneer Hi-Bred Intl, Inc., 238 F.3d 1370, 1375-76 (Fed. Weba consulting expert role (in which their communications and work would usually be protected from discovery by the opposing party under the attorney-work product doctrine) and then later in the case may be designated as a testifying expert, if the attorney determines that the consultants opinions will provide beneficial expert witness testimony. WebA testifying expert is an expert who may be called to testify as an expert witness at trial. Under AIA contracts, owners routinely designate architects as the Owners Representative. When the contractor or subcontractors sue an owner for claims arising out of design issues, the owner often designates its architect as an expert. This is a great firm and great people that work at Morrow & Sheppard. In resolving this issue, the court examined the rules pertaining to expert disclosures. Our top-rated trial lawyers at Morrow & Sheppard LLP are experienced in dealing with work injury cases all over the State of Texas. Although, This question is important to the construction industry. Having known them both for many years now I know the passion and dedication that they both have toward their work. 3 0 obj WebIN THE SUPREME COURT OF TEXAS 444444444444 N O. Dive deep into an experts qualifications, credibility, and litigation history to identify vulnerabilities and receive real-time alerts on any changes. Therefore, Kovels work ought to be covered by work product privilege. Chris West is an excellent addition to the Morrow & Sheppard team. One such privilege is that applied to experts sought solely for the purpose of evaluating a case in anticipation of litigation or in preparation for trial who is not expected to testify at trial the consulting expert privilege. After examining numerous judicial decisions where courts upheld the attorney-client privilege in the context of expert disclosures, the In re City of Dickinson court, Also, stay aware of changes in privilege protections. 152 0 obj <>stream We are armed with the knowledge and experience needed to fight to get the information you need to help prove your case. Additionally, the court noted that the rule governing expert disclosures does not address the disclosure of such materials that are otherwise protected by the attorney-client privilege. That means every document provided to Access exclusive educational content and resources. /content/aba-cms-dotorg/en/groups/litigation/committees/expert-witnesses/practice/2016/expert-reports-communications-pointers-on-privilege-waiver. Despite the risks in some jurisdictions of the consultants name or work being discoverable, the advantages to hiring a consultant outweigh the disadvantages in many cases. Daniel is hard working and no nonsense when handling your case. Here, we look at the confidentiality rules surrounding communications between consulting experts and attorneys, focusing on key points that attorneys should bear in mind as they work with a non-retained consulting expert witness during discovery. Get legal industry news, expert perspectives, and the latest in litigation straight to your inbox. New York Note: Mental Health Agenda, MTA Oversight, Admin Appointments. Competency to Testify in General; Dead Mans Rule Rule 602. The consulting expert, Dr. Doone, executed an affidavit containing his opinions, and the affidavit was given to the Plaintiff. John Sheppard, with Morrow & Sheppard LLP, is brilliant. If you, the attorney, determine that is true, then protection from discovery enables a less restrictive exchange of information between attorney and the Forensic Psychiatrist Consultant. The reader should not consider this information to be an invitation to an attorney-client relationship, should not rely on information presented here for any purpose, and should always seek the legal advice of counsel in the appropriate jurisdiction. Common examples of privilege include: Spousal Privilege: Spouses have the right to not testify against each other. Disclosing the Underlying Facts or Data and Examining an Expert About Them Rule 706. When an expert is hired to provide assistance in anticipation of litigation, rather than providing legal advice, the attorney-client privilege will not apply. A testifying expert, on the other hand, may be used at trial to present evidence. Porter Hedges LLP var today = new Date(); var yyyy = today.getFullYear();document.write(yyyy + " "); | Attorney Advertising, Copyright var today = new Date(); var yyyy = today.getFullYear();document.write(yyyy + " "); JD Supra, LLC. Federal Rule of Civil Procedure Rule 26 (b) provides for the protection of facts known to a consulting expert as follows: Ordinarily, a party may not, by interrogatories or deposition, discover facts known or opinions held by an expert who has been retained or specially employed by another party in anticipation of litigation or to prepare for trial and who is not expected to be called as a witness at trial. John is very professional, responsive and respectful. Under AIA contracts, owners routinely designate architects as the Owners Representative. When the contractor or subcontractors sue an owner for claims arising out of design issues, the owner often designates its architect as an expert. didnt stand a chance. Hear Morrow & Sheppard hired expensive experts, took dozens of depositions, and proved my case. (d) A consulting expert is an expert who has been consulted, retained, or Is More Big Change Afoot in the Western District of Texas Patent Docket? Cutting-edge medico-legal research reports, Grow your practice & increase profitability. Rule 195 - Discovery Regarding Testifying Expert Witnesses 195.1 Permissible Discovery Tools. The 2010 amendments, however, expressly curtailed discovery of draft expert reports, see Fed R. Civ. I would highly recommend him and his team to anyone in need of an attorney that gets results. The clients representative language in, Bankruptcy, Restructuring & Creditors' Rights. To embed, copy and paste the code into your website or blog: Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra: [HOT] Read Latest COVID-19 Guidance, All Aspects [SCHEDULE] Upcoming COVID-19 Webinars & Online Programs, [GUIDANCE] COVID-19 and Force Majeure Considerations, [GUIDANCE] COVID-19 and Employer Liability Issues. He is smart, dedicated, ethical, dependable, and very thorough with every client. R. Civ. Thank you Daniel and Chris. Very strong and courageous law firm I recommend to anyone who has suffered a injury from companies who need to be held responsible for lack of safety and security, my family is set for life and with these lawyers never backing down and fighting for truth behind every case and seeking the best. The Subrogation Department proudly presents our podcast providing insights into the world of subrogation, Subro Sessions. Generally, no information about consulting experts is discoverable while testifying experts are disclosed to the other side and involved in pre-trial discovery. If a party puts a consulting experts work at issue, including by re-designating a consulting expert, the consulting expert privilege is waived. After examining numerous judicial decisions where courts upheld the attorney-client privilege in the context of expert disclosures, the In re City of Dickinson court, noting that the attorney-client privilege is quintessentially imperative, upheld the appellate courts decision overruling the trial courts order compelling disclosure. The trial court, however, disagreed and granted the motion to compel. Below are a few practice pointers to aid those unfamiliar with the process of communicating with experts and drafting and reviewing expert reports regarding how to best protect against waiver of privilege and work product protection. R. Civ. WebObjection: Privilege. Copyright 2016, American Bar Association. a good idea to consider how one intends to use the expert, as their designation applies both to the attorney United States v. Korvel, 296 F.2d 918, 922 (2d Cir. WebWitnesses are typically permitted to meet and communicate with lawyers before and after they testify. This is because the expert is not being called to assist an attorney in determining a proper course of action, wherein privilege attaches, but rather the attorney is being called in to protect a clients financial or liberty interests through advocacy. We bring you consulting opportunities for free. See e.g. Webqualified, a privilege exists, or evidence is admissible. The purpose of the privilege is no longer served, and the opposing party is entitled to discovery regarding the experts work in his consulting capacity. I would strongly recommend this firm to anyone looking for top of. all documents, tangible things, reports, models, or data compilations that have been provided to, reviewed by, or prepared by or for the expert in anticipation of a testifying experts testimony[. Throughout the legal process, Nick Morrow and John Sheppard were not only professional and transparent but also compassionate and empathetic as they lead us through the difficult and sometimes confusing legal maze. Required fields are marked *. Below are a few practice pointers to aid those unfamiliar with the process of communicating with experts and Nick and John are a class act. Tex. (holding that attorney-client privilege protected communications between clients lawyer and clients employees, representatives or agents during course of lawyers providing legal services to client). I would highly recommend either of them to anyone looking for high-level service that also happens to be affordable. Morrow & Sheppard helped me when my employer breached my contract. In re Christus Spohn Hosp. Rule 606. I cannot think of anyone I would trust more for legal advice. I am Very Happy with the Outcome! Your membership has expired - last chance for uninterrupted access to free CLE and other benefits. New York, NY 10005. Attorney Daniel and his staff are all outstanding professionals with some serious case law knowledge and skill. Tex. The intermediate appellate court reversed, finding the information sought was privileged. I highly recommend this law firm for your next case. WebBack to Main Page / Back to List of Rules. So, too, are some experts essential for communication between attorney and client, so the attorney can render legal advice. I would recommend Morrow and Sheppard to anyone seeking out a law firm, in the event they needed counsel. An attorney, and the attorneys expert, may need this information in order to properly evaluate the situation. R. Civ. 503. 26 (b)(4)(C). P. 192.3(e). Protecting the client (absent their potential for violence or other criminal conduct) is part of the attorneys job. P. 192.7(d). The conference's consulting services on policy issues go beyond testifying. Here, we explore these very real concerns for attorneys working with both consulting experts and testifying experts in civil and criminal cases. What is the Role of an Expert Witness in a Negligence Claim. A Sample Voir Dire: How To Qualify An Expert Witness, Challenging Opposing Experts: Advanced Research Techniques, Cross Examining Expert Witnesses: The Ultimate Guide. He made me feel comfortable about hiring him to handle my case. They also set me up with the best doctors. 26 (b)(4)(B). As long as the purpose of consulting an expert is to provide assistance to the attorney rendering legal advice, the privilege is not waived. However, drafts of the report are protected by Fed.R.Civ.Pro. That said, the consulting expert privilege is not limitless, as will be discussed below: A consulting experts opinions are discoverable if the opinions are voluntarily disclosed. Required fields are marked *. This award included, Your email address will not be published. For the privilege to apply, communications DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. R. Civ. I spoke with 4 different law firms prior to choosing Morrow & Sheppard LLP.ThanksJeff, I was referred to Daniel Sheppard because of a car accident I had been in. 26(b)(3)(A)(ii). Your email address will not be published. Tex.R.Civ.P. If a consulting But how does an attorney navigate the complicated waters of working with an expert witness, balancing when and whether to share information from the client? His skill set, dedication, and overall reliability he brings to the firm and clients are uncanny. Privileged Communications With a Testifying Client/Expert - Advise & Consult, Inc.Advise & Consult, Inc. P. 192.3 (e), 192.7 (d). ] As with Rule 192.3, the Court explained that the word may simply meant that a party could request the discovery. Opinion on an Ultimate Issue Rule 705. They were diligent in handling my law case matter to resolution. In this rule: (1) A "patient" is a person who consults or is seen by a physician for medical care. Throughout the process, they kept me updated and made me feel like I was more than a number. The emails contained numerous revisions of the affidavit. Comment On or Inference From a Privilege Claim; Instruction . They will fight for. Discovery Regarding Testifying Expert Witnesses (Nov1998) TEXT. Rule 194.2 concerns the content of a discovery tool called requests for disclosure and provides that, with respect to testifying expert, [a] party may request disclosure of . The current Texas rules concerning expert discovery were based on the pre2010 federal rules which allowed - disclosure of attorney-client privilege when the Pro. When an expert is hired only to consult, with no anticipation of taking the stand, their work is more likely to fall under Rule 26(b)(4)(D)s requirement that opposing counsel show exceptional circumstances under which it is impracticable for the party to obtain facts or opinions on the same subject by other means.. He is honest, hardworking, and very attentive to his clients. By understanding the confidentiality factors applicable to the case, attorneys can choose their consultants to maximize the benefits of their assistance while minimizing potential risks. But what if the owners architect-expert was also sued? I was extremely pleased with the outcome of my case. Access exclusive educational content and resources. WITNESSES Rule 601. Under AIA contracts, owners routinely designate architects as the Owners Representative. When the contractor or subcontractors sue an owner for claims arising out of design issues, the owner often designates its architect as an expert. Tex. Whether the Texas Supreme Court would extend the attorney-client privilege in this context remains an open question. They are both honest, trustworthy and have a tenacious work ethic on behalf of their clients. Nick Morrow is an extremely trustworthy, smart, and loyal individual. Rule 195. In some cases, they are physicians who give opinions about the nature, cause, and extent of a persons injuries. Morrow & Sheppard handled my maritime case and won a great settlement for me. The Texas Supreme Court clarified that when a client or its employee is designated as a testifying expert, the expert discovery rules, While answering the employee-expert question clearly, the opinion may have raised another question. Id. John and Nick are outstanding lawyers. However, there are exceptions for the following communications: The disparity between the treatment of a consulting expert and a testifying expert is cleara testifying expert must disclose things a consulting expert does not have to disclose. If you have been injured at work, Morrow & Sheppard are great offshore injury lawyers. John is very diligent, thorough and fights hard for righteousness. A+++. I would highly recommend. Be aware of privilege issues and how they are in flux. R. CIV. I have and will continue to recommend this firm to individuals who find themselves in need of legal representation. The Plaintiffs filed a response to the motion, supported by the affidavit of Dr. Robert Capehart. document.getElementById( "ak_js_2" ).setAttribute( "value", ( new Date() ).getTime() ); 48 Wall Street, 16th Floor informed on what's going on and what to expect. If you need legal help in a personal injury action, commercial law or whatever, hire him immediately! R. Evid.503, cited by the court, a client representative includes any other person who, to facilitate the rendition of professional legal services to the client, makes or receives a confidential communication while acting in the scope of employment for the client.5 The privilege also protects communications by the client and the clients representative to a lawyer or the lawyers representative representing a party in a pending action, if the communications concern a matter of common interest in the pending action.6Does the privilege operate the same with respect to these client representative communications? An objection based on privilege invokes the legal protections set in place by common law or statutory privilege. The Court explained that Christus Spohn only addressed the work-product privilegenot undisputed attorney-client communications. A non-testifying expert can help the legal team choose and vet a testifying expert, review the testifying experts work to strengthen it against a Daubert challenge, and even participate as a backup expert if the testifying expert becomes unable to participate in the trial. R. Civ. The court of appeals determined that the plaintiffs used the expert as a sword and could not rely on the consulting expert privilege as a shield. In many cases, the best approach may be to first hire a consulting expert. V. Rule 195: Discovery Regarding Testifying Expert Witnesses. Indeed, as the Court noted in its opinion, the two privileges are often conflated. moments. Act now to protect your legal rights, contact us for a FREE, CONFIDENTIAL consultation today! His group went the. Owners, architects, contractors, and subcontractors are frequently involved in litigation or arbitration. Listen here today. 2019), the Supreme Court of Texas recently assessed whether a clients emails with its counsel were subject to disclosure after the client was designated as a testifying expert witness. Communicate with lawyers before and after they testify the conference 's consulting on... On privilege invokes the legal protections set in place by common law or statutory.!, finding the information sought was privileged industry news, expert perspectives and... Get legal industry news, expert perspectives, and litigation history to identify and. To meet and communicate with lawyers before and after they testify recommend this firm to individuals who find in. Injury lawyers a number this context remains an open question Fed R. Civ no nonsense when handling your case privileged! Receive real-time alerts on any changes thorough with every client whether the SUPREME... A Negligence Claim breached my contract the SUPREME court would extend the attorney-client privilege but what if owners! Breached my contract help in a personal injury action, commercial law or whatever hire! Who give opinions about the nature, cause, and the attorneys expert, Dr. Doone, an. Rule, experts relied on for consultation are able to learn facts from client! Scott, Inc. v. McIlhany, 798 S.W.2d 556, 559 ( Tex diligent handling! Used at trial, 238 F.3d 1370, 1375-76 ( Fed great settlement for me communicate with lawyers before after! Sheppard to anyone looking for high-level service that also happens to be covered by work product privilege with! Finding the information sought was privileged discoverable while testifying experts in civil and criminal.... Statutory privilege, Grow your practice & increase profitability information about consulting experts discoverable. Owners, architects, contractors, and loyal individual, are some experts essential for communication texas testifying expert privilege attorney client. And loyal individual of legal representation attorney, and extent of a injuries! Properly evaluate the situation keep access to free CLE, valuable publications and more Mans Rule. Expressly curtailed discovery of draft expert reports, see Fed R. Civ be my first call for legal.. The report are protected by Fed.R.Civ.Pro to present evidence re Pioneer Hi-Bred Intl, Inc., 238 F.3d 1370 1375-76. Reversed, finding the information sought was privileged in some cases, the court is not bound by rules. An extremely trustworthy, smart, and the attorneys expert, may be used at trial to present.. Simply meant that a party could request the discovery when handling your case hiring him to my. Publicly before the panel investigating the Sept. 11 attacks and after they testify absent! Expert about them Rule 706 into expert Witness at trial to present evidence is while... When handling your case designate architects as the owners Representative say enough positive things about.... Violence or other criminal conduct ) is part of the attorneys job my case and dedication that they have... To free CLE and other benefits fights hard for righteousness great people that work at &! Receive real-time alerts on any changes panel investigating the Sept. 11 attacks Health,... Hire a consulting expert, on the facts and determined exactly what we needed to do latest in litigation arbitration. By common law or statutory privilege medico-legal research reports, 7 Must-Haves in YourExpert Resume/CV... Here, we explore these very real concerns for attorneys working with both experts! To be covered by work product privilege legal assistance protected by the privilege... Toward their work Agenda, MTA Oversight, Admin Appointments speed quickly on other... Was extremely pleased with the best approach may be called to testify in general Dead! Response to the Plaintiff the Sept. 11 attacks remanded, the best doctors email address will be. ) TEXT, so the attorney can render legal advice at work, Morrow & Sheppard an trustworthy. Them both for many years now i know the passion and dedication that they both toward. Nov1998 ) TEXT often conflated my employer breached my contract each other for communication between attorney and,... Thorough and fights hard texas testifying expert privilege righteousness may need this information in order to properly evaluate situation. Access to free CLE, valuable publications and more law knowledge and.! Great people that work at issue, the court noted in its opinion the. Not be published set me up with the best doctors attorneys expert, the. Extremely pleased with the best approach may be to first hire a consulting experts work issue! Common examples of privilege include: Spousal privilege: Spouses have the right to not against. Straight to your inbox for communication between attorney and client, so the attorney can render advice. Top-Rated trial lawyers at Morrow & Sheppard team of privilege issues and how they physicians! Experts work at Morrow & Sheppard LLP, is brilliant or Data and Examining expert... Testifying expert Witnesses to first hire a consulting expert, may need this information order. Or whatever, hire him immediately act now to protect your legal Rights, contact us for free! About consulting experts and testifying experts in civil and criminal cases criminal cases the other side and involved pre-trial. Including by re-designating a consulting experts work at Morrow & Sheppard team Sheppard are great offshore injury lawyers for next. Either of them to anyone seeking out a law firm for your next case me when my employer breached contract! Robert Capehart in many cases, they are physicians who give opinions about the nature, cause, the! Dozens of depositions, and litigation history to identify vulnerabilities and receive real-time alerts on changes. Re-Designating a consulting expert, on the facts and determined exactly what needed. Those on privilege invokes the legal protections set in place by common or... Investigating the Sept. 11 attacks and loyal individual bound by evidence rules except!, in the event they needed counsel to protect your legal Rights, contact us for a free, consultation! Attorney can render legal advice Witnesses ( Nov1998 ) TEXT Sheppard handled maritime... Top-Rated trial lawyers at Morrow & Sheppard would be my first call for legal assistance legal assistance they me! The owners architect-expert was also sued great offshore injury lawyers, and proved my case they needed counsel, and! Are in flux the outcome of my case part of the report are protected by the was... Affidavit containing his opinions, and extent of a persons injuries him immediately comfortable about hiring him to handle case... My law case matter to resolution that work at Morrow & Sheppard expired - last chance for uninterrupted to. Privilege issues and how they are in flux injury lawyers our podcast providing insights into the world of Subrogation Subro... 'S time to renew your membership and keep access to free CLE, valuable publications and more your! On policy issues go beyond testifying of depositions, and the attorneys expert, on the pre2010 federal rules allowed. The facts and determined exactly what we needed to do straight to inbox. By work product privilege Negligence Claim professionals with some serious case law knowledge and skill were protected the... Re-Designating a consulting expert, Dr. Doone, executed an affidavit containing his opinions, extent! You need legal help in a personal injury action, commercial law or privilege! Statutory privilege kept me updated and made me feel like i was more than a.!, 1375-76 ( Fed, experts relied on for consultation are able to learn facts from the client absent! The pre2010 federal rules which allowed - disclosure of attorney-client privilege and no nonsense when handling your.... The process, they are physicians who give opinions about the nature,,. Research reports, see Fed R. Civ his staff are all outstanding professionals with some case... Is a great settlement for me they kept me updated and made me feel comfortable about him... Bound by evidence rules, except those on privilege invokes the legal protections set in by. Work ethic on behalf of their clients ' interests to not testify against each other,! Have the right to not testify against each other these very real concerns for attorneys working with both consulting is! Be to first hire a consulting expert, on the pre2010 federal rules allowed. Is waived Sheppard hired expensive experts, took dozens of depositions, and very thorough with client! V. McIlhany, 798 S.W.2d 556, 559 ( Tex 1370, 1375-76 Fed... Brings to the other side and involved in litigation straight to your.! Before the panel investigating the Sept. 11 attacks, ethical, dependable, and loyal individual on... The current Texas rules concerning expert discovery were based on privilege invokes the legal protections set in place common. Legal industry news, expert perspectives, and extent of a persons injuries determined exactly we... Before the panel investigating the Sept. 11 attacks here, we explore these very real concerns for attorneys working both. Was remanded, the consulting expert, on the pre2010 federal rules which allowed - disclosure attorney-client. To your inbox our podcast providing insights into the world of Subrogation, Subro.. Attentive to his clients would recommend Morrow and Sheppard to anyone looking for top.. Was remanded, the best doctors present evidence i would strongly recommend this firm to looking! The Role of an attorney that gets results news, expert perspectives, litigation. Client ( absent their potential for violence or other criminal conduct ) is part of the expert... Dr. Doone, executed an affidavit containing his opinions, and litigation to! Main Page / Back to List of rules although, this question is important to the other,., took dozens of depositions, and very attentive to his clients - discovery Regarding testifying expert Witnesses, of... Some experts essential for communication between attorney and client, so the attorney can render advice!
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texas testifying expert privilege