Discovery regarding expert witnesses is governed by Tennessee’s Rules of Civil Procedure, Rule 26.02. TENN. CODE ANN. § 26.02 (West 20217). This rule allows for discovery to be made into the amount of compensation that the expert is being paid to be an expert witness. Id. Case law states that the policy behind the rule is to allow discovery of “any relevant matter that is not privileged.” Vythoulkas v. Vanderbilt University Hosp., 693 S.W.2d 350 (Tenn. Ct. App. 1985). Further, the court has found that disclosure of an expert’s annual income was relevant to show bias. Laseter v. Regan, 481 S.W.3d 613 (Tenn. Ct. App. 2014).
