I have come across two paralegal practices that have been most helpful in avoiding time crunch problems caused by expert report deadlines.
Sometimes the expert forgets to ask about his report’s due date, or the expert incorrectly figured the case settle because he hadn’t heard from his client attorney in 18 months. Sometimes the attorney forgets to tell the expert about the expert’s report due date.
Once I was notified that my report on a major case was due in 12 days, which included two weekends and four days while I was scheduled on a site exam in another state not to mention my normal day-to-day workload. Fortunately, I was able available to work “24/7” the weekend before the due date (on a Monday) because my wife hadn’t planned an outing. The opposing attorney would not agree to an extension.
To avoid possibly missing an expert report deadline, one paralegal’s practice was to forward the court scheduling order to me when it was issued and when it was modified. The court scheduling order almost always contains deadlines.
Another paralegal’s practice was to add a reminder note to the bottom of her emails to me about the due date of my report.
Both paralegal practices allow the expert to: (1) schedule report preparation time, and (2) confirm the report due date is calendared. Engineering experts are often on the road for a week at a time and booked solid, thus suitable advance notice of report due dates is important.