Factual basis of the claim or defense.
Legal theories upon which the claim is based.
Names, addresses, and telephone numbers of witnesses
expected to be called at trial.
Names and addresses of all persons whom the party believes
have knowledge or information relevant to the claims, and the
nature of the knowledge or information each individual is
believed to possess.
Names and addresses of all persons who have given
statements.
Name and addresses of each person the disclosing party
expects to call as an expert at trial, the subject matter, the
substance of facts and opinions, a summary of the grounds for
each opinion, the qualifications of the expert, and the name
and address of the custodian of copies of any reports prepared
by the expert.
Computation and the measure of damage and the documents or
testimony on which such computation and measure are based,
together with the names and addresses of all damage experts.
Existence, location, custodian, and general description of
any tangible evidence or relevant documents that the
disclosing party plans to use at trial and relevant insurance
agreements.
List of documents, or in the case of voluminous documentary
information, a list of categories of documents, known by the
disclosing party to exist, whether or not in the party's
possession, custody, or control, which are relevant to or
appear reasonably calculated to lead to the discovery of
admissible evidence, and the date upon which those documents
will be made available for inspection and copying by the other
parties.