CEDANT v. UNITED STATES

No. 21-12661.

75 F.4th 1314 (2023)

Cajule CEDANT, Plaintiff-Appellant, v. UNITED STATES of America, Defendant-Appellee.

United States Court of Appeals, Eleventh Circuit.

Filed: August 4, 2023.


Attorney(s) appearing for the Case

Chad Andrew Barr , Law Office of Chad A. Barr, PA, Altamonte Springs, FL, Hector Miguel Piedra , Paul Gustave Totten , Steinger Greene & Feiner, PA, Fort Lauderdale, FL, for Plaintiff-Appellant.

Randall Dana Katz , U.S. Attorney's Office, Fort Lauderdale, FL, Nicholas S. Crown , DOJ-CIV, Civil Division, Appellate Staff, Washington, DC, Shahrzad Daneshvar , Emily M. Smachetti , Suzette A. Smikle , DOJ-USAO, Miami, FL, Daniel Matzkin , Lisa Tobin Rubio , U.S. Attorney Service — Southern District of Florida, U.S. Attorney Service — SFL, Miami, FL, for Defendant-Appellee.

Before Jill Pryor, Newsom, and Grant, Circuit Judges.


Federal Rule of Civil Procedure 26(a)(2) outlines two types of pretrial disclosures for expert witnesses—one lengthy and one more sparing. Without guidance from this Court, district judges have split on when these witnesses must complete more detailed Rule 26(a)(2)(B) written reports instead of the less onerous Rule...

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