Initial Disclosures Federal Court

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					                              IN THE UNITED STATES DISTRICT COURT
                              FOR THE DISTRICT OF MASSACHUSETTS

_____                                              *

          Petitioner                               *

v.                                                 *       NO: XXXX

_____                                              *

          Respondent.                              *

          *          *         *    *      *       *       *      *       *      *       *

                         PETITIONER _____’S EXPERT WITNESS DISCLOSURE


          Petitioner, _____, (_____), by his undersigned attorneys, in accordance with the May 30,

2002 Amended Order Regulating Non-Jury Trial and Federal Rule of Civil Procedure 26, files

this Expert Witness Disclosure and states as follows:

          1.         _____ designates the following expert witness to testify on his behalf:

                                           _____, Ph.D.


          2.         _____ second Verified Report is attached. The Court already has a copy of _____

Initial Report. The Respondent’s expert witness disclosure has not been provided at the time of

filing this disclosure. Because the Respondent has the burden of establishing her alleged Articles

13(b) and 20 defenses, _____ may require to rebut any such disclosures and he will do so in a

timely manner. With these provisos, the attached Verified Report contains a complete statement

of _____ opinions formulated to date to be expressed at trial and the bases and reasons therefor;

the data or other information considered by _____ in informing the opinion; any exhibits to be

used as a summary of or support for the opinions; the qualifications of _____, including a list of

all publications authored by _____ within the preceding ten years; the compensation to be paid



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for the study and testimony; and the listing of any other cases in which _____ has testified as an

expert at trial or by deposition within the preceding four years.

          3.         _____ designates the following hybrid expert witness to testify on his behalf:

                                                   _____
                                                   Sweden

          4.         _____ is _____ Swedish attorney. He is familiar with Swedish family law and

international private law and is aware of the court orders in this case. _____ Affidavit is

attached.

          5.         _____ reserves the right to rely on the testimony of any of the Respondent’s

experts.       Furthermore, _____ reserves the right to rely on the testimony of any of the

Respondent’s hybrid fact and/or expert witnesses.

                                                   Respectfully submitted,
                                                   _____
                                                   By his attorneys,


                                                   ____________________________________
                                                   _____, Esquire




                                                   ____________________________________
                                                   _____, Esquire

                                          CERTIFICATE OF SERVICE

          I HEREBY CERTIFY that on this ______ day of __________________, 2002, a copy of

the Petitioner _____ Expert Witness Disclosure, with all attachments thereto, was mailed, first-

class, postage prepaid, to _____.




                                                          _______________________________
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                              _____




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