In the case of Lead GHR Enter's, Inc. v. American States Ins. Co., 2014 WL 1246499 *3 (D.S.D. March 25, 2014)(Duffy, USMJ), a U.S. Magistrate Judge saw no distinction in how Federal Rule 26 requires disclosures from the experts to whom it applies.
If Rule 26 applies to one expert, it applies alike to all experts subject to that Rule. That includes rebuttal experts as well as experts in your case-in-chief.
This ruling seems to be the majority view of the question.
In this particular case, moreover, the expert in question was not really offered just in rebuttal. Rather, the party disclosing him was attempting to use him "as an initial expert witness." Lead GHR Enter's, Inc. v. American States Ins. Co., 2014 WL 1246499 *4 (D.S.D. March 25, 2014). Needless to say, this turn of events did not change the ruling.
The ruling had already been made: Rule 26 requirements apply to experts who have been disclosed under Rule 26. That is the ruling. Period.
P.S.
Subject to the party producing the witness to be redeposed and paying certain expenses, the expert was allowed as an initial expert witness and not just in rebuttal.
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