It is never appropriate to send the expert anything short of ALL of the available documents that are relevant to her testimony. If you do not send all of the relevant documents to the expert, the expert will be subject to a devastating cross-examination in which defense counsel will make it appear that the plaintiff’s attorney is simply using the expert as a puppet to espouse the theories developed by the plaintiff’s attorney and then sent the material to support that theory.
The expert witness should receive: the complete underlying file; all pleadings and discovery in the case; all depositions of all persons in the case; any other materials which might be relevant. Keep an itemized list of what was sent, so you can make sure that any expert who may be asked to testify on any of the same or related issues has received the identical materials.
If you do not want the expert to review all of the materials that you sent to her, you can orally tell the expert what documents she might want to focus on. Otherwise, the expert may think you want her to review the entire file and will run up a big tab on you.
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