Expert Witness: Tax Returns & 1099’s
The court in SHARON R. OLSON v. STATE FARM FIRE COMPANY, Case No.C14-0786RSM United States District Court, W.D. Washington, Seattle (February 23, 2015) dealt with a motion to quash a broad subpoena for the tax records and 1099’s of a medical expert.
The court denied the attempt to force the medical expert to produce her income tax returns and 1099’s and stated:
Defendant next objects to the subpoena to the extent it seeks all financial records, including tax returns and 1099s, showing all income earned from forensic work within the last three (3) years. The Court agrees that this portion of the subpoena is overbroad. There is no dispute that Plaintiff is entitled to information about Dr. Reif’s income and the portion of such income attributable to work as an expert witness. Indeed, it is standard practice for litigants to inquire about such matters at expert witness depositions. However, the term “all financial records . . . showing all income earned from forensic work” is overbroad and unduly burdensome as it appears to require Dr. Reif to produce a wide range of documents, including any of her bank statements reflecting such income.
Likewise, the Court finds that Dr. Reif’s complete tax returns are irrelevant and overbroad for the purpose requested here.