A Guide to Discovery Rules

Federal and State-by-State Guidelines that Expert Witnesses Should Know (Part II of II)

Navigating the maze of discovery rules in economic damage cases can be daunting. Professionals often face a patchwork of regulations across jurisdictions. This two-part article provides an overview of key discovery rules applicable in federal courts and each of the 50 U.S. states. Read Part I here.

In this second part of the article, the rules for Mayland through Wyoming are summarized.

Maryland

Maryland’s discovery rules are codified in its Rules of Procedure, with a strong emphasis on early disclosures and efficient case management. Discoverable items include e-mails, business memos, draft proposals, and other relevant electronic or written records.

For expert witnesses working on engagements heard before Maryland courts, this means that final expert reports, meeting notes, and e-mails that are not privileged are generally discoverable. Furthermore, Maryland Rule 2-402(g) allows discovery of the expert’s final report, the expert’s qualifications, and the facts or data considered by the expert. Draft expert reports are generally not discoverable, per Maryland Rule 2-402(g)(1)(C), which protects draft reports from discovery and aligns with the federal work-product doctrine.[1]

Massachusetts

Massachusetts discovery rules are governed by the Massachusetts Rules of Civil Procedure, which emphasize proportionality and reasonableness. Discoverable materials include e-mails, meeting minutes, draft reports, and other electronic and written communications relevant to the case.

For expert witnesses working on engagements heard before Massachusetts courts, this means that final expert reports, meeting notes, and e-mails that are not privileged are generally discoverable. Under Massachusetts Rule of Civil Procedure 26(b)(4), parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action, including the existence, description, nature, custody, condition, and location of any books, documents, or other tangible things and the identity and location of persons having knowledge of any discoverable matter. Draft expert reports are generally not discoverable, per Massachusetts Rule of Civil Procedure 26(b)(4)(B), which protects draft reports from discovery and aligns with the federal work-product doctrine.[2]

Michigan

Michigan’s discovery rules, under the Michigan Court Rules, provide guidance on the scope and limitations of discovery. Items such as e-mails, internal communications, draft reports, and meeting notes are often discoverable. Under Michigan Court Rule 2.302(B)(4), a party may obtain discovery of facts known and opinions held by an expert who is expected to testify at trial, including the subject matter and substance of the facts and opinions to which the expert is expected to testify.

For expert witnesses working on engagements heard before Michigan courts, this means that final expert reports, meeting notes, and e-mails that are not privileged are generally discoverable. Draft expert reports are generally not discoverable.[3]

Minnesota

Discovery in Minnesota state courts is governed by the Minnesota Rules of Civil Procedure. Discoverable materials include e-mails, draft analyses, meeting summaries, and ESI pertinent to the case.

For expert witnesses working on engagements heard before Minnesota courts, this means that final expert reports, meeting notes, and e-mails that are not privileged are generally discoverable. Under Minnesota Rule of Civil Procedure 26.01(a)(2)(B), a party must disclose to the other parties the identity of any expert witness it may use at trial to present evidence under Minnesota Rule of Evidence 702, 703, or 705, and provide a written report prepared and signed by the expert. Draft expert reports are generally not discoverable. Minnesota Rule of Civil Procedure 26.02(f)(2) protects draft reports from discovery, aligning with the federal work-product doctrine.[4]

Mississippi

Mississippi’s discovery rules are outlined in the Mississippi Rules of Civil Procedure, allowing for the discovery of e-mails, draft documents, meeting notes, and other case-relevant materials.

For expert witnesses working on engagements heard before Mississippi courts, this means that final expert reports, meeting notes, and e-mails that are not privileged are generally discoverable. Under Mississippi Rule of Civil Procedure 26(b)(4)(A), a party may obtain discovery of facts known and opinions held by an expert who is expected to testify at trial, including the subject matter and substance of the facts and opinions to which the expert is expected to testify. Draft expert reports are generally not discoverable.[5]

Missouri

Missouri follows the Missouri Rules of Civil Procedure, with discoverable materials including e-mails, meeting notes, draft financial records, and other written or electronic documents.

For expert witnesses working on engagements heard before Missouri courts, this means that final expert reports, the facts or data considered by the expert, meeting notes, and e-mails that are not privileged are generally discoverable, and that draft expert reports are generally not discoverable.[6]

Montana

Montana’s discovery rules align with the Montana Rules of Civil Procedure, permitting the discovery of e-mails, draft business records, meeting summaries, and other relevant materials.

For expert witnesses working on engagements heard before Montana courts, this means that final expert reports, meeting notes, and e-mails that are not privileged are generally discoverable. Under Montana Rule of Civil Procedure 26(b)(4)(A), a party may discover facts known or opinions held by an expert who has been retained or specially employed by another party in anticipation of litigation or preparation for trial and who is expected to be called as a witness at trial. Draft expert reports are generally not discoverable.[7]

Nebraska

Nebraska discovery rules under the Nebraska Court Rules include the discovery of e-mails, draft reports, meeting notes, and other documents relevant to the dispute.

For expert witnesses working on engagements heard before Nebraska courts, this means that final expert reports, meeting notes, and e-mails that are not privileged are generally discoverable. According to Nebraska Court Rule § 6-2204(A), each side must disclose the identity of any expert witness they may use at trial and provide a complete statement of all opinions the expert will express, the basis and reasons for them, the facts or data considered, and any supporting exhibits. Draft expert reports are generally not discoverable.[8]

Nevada

Nevada’s discovery rules, outlined in the Nevada Rules of Civil Procedure, include provisions for the discovery of e-mails, meeting notes, draft proposals, and electronic data.

For expert witnesses working on engagements heard before Nevada courts, this means that final expert reports, meeting notes, and e-mails that are not privileged are generally discoverable. Under Nevada Rule of Civil Procedure 16.1(a)(2)(B), parties must disclose the identity of any expert witness they may use at trial and provide a written report prepared and signed by the witness. This report must contain a complete statement of all opinions the expert will express, the basis and reasons for them, the facts or data considered, and any supporting exhibits. Draft expert reports are generally not discoverable.[9]

New Hampshire

Discovery in New Hampshire is governed by the New Hampshire Rules of Civil Procedure, permitting the discovery of e-mails, draft reports, meeting notes, and other pertinent records.

For expert witnesses working on engagements heard before New Hampshire courts, this means that final expert reports, the facts or data considered by the expert, meeting notes, and e-mails that are not privileged are generally discoverable, and that draft expert reports are generally not discoverable.[10]

New Jersey

New Jersey’s Rules of Court provide discovery guidelines, including the ability to obtain e-mails, internal memos, draft documents, and ESI.

For expert witnesses working on engagements heard before New Jersey courts, this means that final expert reports, meeting notes, and e-mails that are not privileged are generally discoverable. New Jersey Rule of Court 4:10-2(d)(1) mandates that parties are required to disclose the identity of any expert witness they intend to call at trial, along with a summary of the facts and opinions to which the expert is expected to testify. Draft expert reports are generally not discoverable.[11]

New Mexico

Discovery rules in New Mexico follow the New Mexico Rules of Civil Procedure, allowing for the discovery of e-mails, meeting minutes, draft reports, and other case-relevant documents.

For expert witnesses working on engagements heard before New Mexico courts, this means that final expert reports, meeting notes, and e-mails that are not privileged are generally discoverable. Mexico Rule of Civil Procedure 1-026(B)(6) mandates that parties are required to disclose the identity of any expert witness they intend to call at trial, along with a summary of the facts and opinions to which the expert is expected to testify. Draft expert reports are generally not discoverable.[12]

New York

New York’s Civil Practice Law and Rules govern discovery, including the disclosure of e-mails, draft documents, meeting notes, and electronic communications relevant to the dispute.

For expert witnesses working on engagements heard before New York courts, this means that final expert reports may or may not be discoverable. Under CPLR § 3101(d)(1)(i), parties are required to disclose the identity of any expert witness they intend to call at trial, along with “the subject matter on which each expert is expected to testify, the substance of the facts and opinions on which each expert is expected to testify, [and] the qualifications of each expert witness.” This disclosure does not mandate the production of a formal written report prepared by the expert. However, in certain courts, such as New York County’s Commercial Division, specific rules may require a written report prepared and signed by the expert. E-mails and meeting notes that are relevant or pertain to the facts or data considered by the expert are generally discoverable. Draft expert reports are generally not discoverable.[13]

North Carolina

Discovery in North Carolina is guided by the North Carolina Rules of Civil Procedure, permitting the discovery of e-mails, draft proposals, meeting minutes, and other relevant documents.

For expert witnesses working on engagements heard before North Carolina courts, final expert reports and the facts or data considered by the expert are generally discoverable. E-mails and meeting notes may be discoverable if they pertain to the expert’s opinions or facts considered, but communications protected by privilege or the work-product doctrine are generally not discoverable. Draft expert reports are generally not discoverable .[14]

North Dakota

North Dakota follows the North Dakota Rules of Civil Procedure, allowing for the discovery of e-mails, meeting notes, draft financial records, and other pertinent materials.

For expert witnesses working on engagements heard before North Dakota courts, this means that final expert reports, meeting notes, and e-mails that are not privileged are generally discoverable. North Dakota Rule of Civil Procedure 26(b)(4)(A) mandates that parties are required to disclose the identity of any expert witness they intend to call at trial, along with a summary of the facts and opinions to which the expert is expected to testify. Draft expert reports are generally not discoverable.[15]

Ohio

Ohio’s discovery rules, under the Ohio Rules of Civil Procedure, include provisions for obtaining e-mails, draft reports, meeting minutes, and ESI.

For expert witnesses working on engagements heard before Ohio courts, this means that final expert reports, the facts or data considered by the expert, meeting notes, and e-mails that are not privileged are generally discoverable, and that draft expert reports are generally not discoverable.[16]

Oklahoma

Discovery in Oklahoma follows the Oklahoma Rules of Civil Procedure, with discoverable items including e-mails, meeting notes, draft reports, and other written or electronic materials.

For expert witnesses working on engagements heard before Oklahoma courts, this means that final expert reports, the facts or data considered by the expert, meeting notes, and e-mails that are not privileged are generally discoverable. Parties are required to disclose the identity of any expert witness they intend to call at trial, along with a written report prepared and signed by the expert. This report must include a complete statement of all opinions the expert will express and the basis and reasons for them. This is mandated by Oklahoma Statutes Title 12, Section 3226(B)(4)(c). Draft expert reports are generally not discoverable.[17]

Oregon

Oregon’s discovery rules are outlined in the Oregon Rules of Civil Procedure, allowing for the discovery of e-mails, draft documents, meeting notes, and other case-relevant records.

For expert witnesses working on engagements heard before Oregon courts, this means that final expert reports, the facts or data considered by the expert, draft expert reports, e-mails, and meeting notes are generally not discoverable. Oregon does not permit formal discovery of expert witnesses. Parties are not required to disclose the identity of any expert witness they intend to call at trial, nor are they required to provide a written report prepared and signed by the expert. This is mandated by Oregon Rule of Civil Procedure 47 E.[18]

Pennsylvania

Pennsylvania discovery rules are governed by the Pennsylvania Rules of Civil Procedure, permitting the discovery of e-mails, meeting minutes, draft analyses, and other relevant materials.

For expert witnesses working on engagements heard before Pennsylvania courts, this means that final expert reports and the facts or data considered by the expert are generally discoverable. Parties are required to disclose the identity of any expert witness they intend to call at trial, along with a written report prepared and signed by the expert. This report must include a complete statement of all opinions the expert will express and the basis and reasons for them. This is mandated by Pennsylvania Rule of Civil Procedure 4003.5(a)(1). Draft expert reports, e-mails, and meeting notes are protected under the work-product doctrine and are generally not discoverable.[19]

Rhode Island

Rhode Island’s discovery rules under the Rhode Island Rules of Civil Procedure include provisions for obtaining e-mails, draft reports, meeting notes, and ESI.

For expert witnesses working on engagements heard before Rhode Island courts, this means that final expert reports and the facts or data considered by the expert are generally discoverable. Parties are required to disclose the identity of any expert witness they intend to call at trial, along with a written report prepared and signed by the expert. This report must include a complete statement of all opinions the expert will express and the basis and reasons for them. This is mandated by Rhode Island Superior Court Rule of Civil Procedure 26(b)(4)(A). Draft expert reports, e-mails, and meeting notes are protected under the work-product doctrine and are generally not discoverable. This protection is outlined in Rhode Island Superior Court Rule of Civil Procedure 26(b)(4)(B).[20]

South Carolina

Discovery in South Carolina follows the South Carolina Rules of Civil Procedure, with discoverable items including e-mails, draft business records, meeting notes, and other pertinent documents.

For expert witnesses working on engagements heard before South Carolina courts, this means that final expert reports and the facts or data considered by the expert is generally discoverable. Parties are required to disclose the identity of any expert witness they intend to call at trial, along with a written report prepared and signed by the expert. This report must include a complete statement of all opinions the expert will express and the basis and reasons for them. This is mandated by Rule 26(b)(4)(A). Draft expert reports, e-mails, and meeting notes are protected under the work-product doctrine and are generally not discoverable.[21]

South Dakota

South Dakota’s discovery rules are outlined in the South Dakota Rules of Civil Procedure, allowing for the discovery of e-mails, meeting notes, draft documents, and electronic communications.

For expert witnesses working on engagements heard before South Dakota courts, this means that final expert reports and the facts or data considered by the expert are generally discoverable only in exceptional circumstances, under which it is impracticable to obtain facts or opinions on the same subject by other means. Draft expert reports, e-mails, and meeting notes are generally not discoverable under the work-product doctrine.[22]

Tennessee

Tennessee discovery rules are governed by the Tennessee Rules of Civil Procedure, including the discovery of e-mails, meeting notes, draft proposals, and other relevant records.

For expert witnesses working on engagements heard before Tennessee courts, this means that final expert reports and the facts or data considered by the expert are generally discoverable. Draft expert reports, e-mails, and meeting notes are generally not discoverable under the work-product doctrine.[23]

Texas

Texas follows the Texas Rules of Civil Procedure, with discoverable materials including e-mails, draft documents, meeting summaries, and other pertinent records.

For expert witnesses working on engagements heard before Texas courts, this means that final expert reports and the facts or data considered by the expert are generally discoverable. Draft expert reports, e-mails, and meeting notes are generally not discoverable under the work-product doctrine.[24]

Utah

Utah’s discovery rules under the Utah Rules of Civil Procedure include provisions for obtaining e-mails, meeting notes, draft reports, and ESI.

For expert witnesses working on engagements heard before Utah courts, this means that final expert reports and the facts or data considered by the expert are generally discoverable. Draft expert reports, e-mails, and meeting notes are generally not discoverable under the work-product doctrine.[25]

Vermont

Vermont discovery rules are outlined in the Vermont Rules of Civil Procedure, permitting the discovery of e-mails, meeting minutes, draft documents, and other relevant records.

For expert witnesses working on engagements heard before Vermont courts, this means that final expert reports and the facts or data considered by the expert are generally discoverable. Draft expert reports, e-mails, and meeting notes are generally not discoverable under the work-product doctrine.[26]

Virginia

Discovery in Virginia is governed by the Virginia Rules of Civil Procedure, allowing for the discovery of e-mails, draft business records, meeting notes, and electronic communications.

For expert witnesses working on engagements heard before Virginia courts, this means that final expert reports and the facts or data considered by the expert are generally discoverable. Draft expert reports, e-mails, and meeting notes are generally not discoverable under the work-product doctrine.[27]

Washington

Washington’s discovery rules follow the Washington Rules of Civil Procedure, permitting the discovery of e-mails, draft analyses, meeting notes, and other pertinent materials.

For expert witnesses working on engagements heard before Washington courts, this means that final expert reports and the facts or data considered by the expert are generally discoverable. Draft expert reports, e-mails, and meeting notes are generally not discoverable under the work-product doctrine.[28]

West Virginia

West Virginia discovery rules are outlined in the West Virginia Rules of Civil Procedure, including the discovery of e-mails, meeting notes, draft proposals, and ESI.

For expert witnesses working on engagements heard before West Virginia courts, this means that final expert reports and the facts or data considered by the expert are generally discoverable. Draft expert reports, e-mails, and meeting notes are generally not discoverable under the work-product doctrine.[29]

Wisconsin

Wisconsin’s discovery rules under the Wisconsin Rules of Civil Procedure include provisions for obtaining e-mails, draft reports, meeting minutes, and other written or electronic materials.

For expert witnesses working on engagements heard before Wisconsin courts, this means that final expert reports and the facts or data considered by the expert are generally discoverable. Draft expert reports, e-mails, and meeting notes are generally not discoverable under the work-product doctrine.[30]

Wyoming

Wyoming discovery rules are governed by the Wyoming Rules of Civil Procedure, allowing for the discovery of e-mails, meeting notes, draft documents, and ESI.

For expert witnesses working on engagements heard before Wyoming courts, this means that final expert reports, meeting notes, and e-mails that are not privileged are generally discoverable. Under Wyoming Rule of Civil Procedure 26(b)(4)(A), a party may discover facts known or opinions held by an expert who has been retained or specially employed by another party in anticipation of litigation or preparation for trial and who is expected to be called as a witness at trial. Draft expert reports are generally not discoverable.[31]

States Following Federal Discoverability Rules

Some states closely follow or have adopted the FRCP regarding discoverability, particularly for documents, e-mails, draft reports, and other ESI. These states include:

• California: Although California has its own Civil Discovery Act, recent amendments have brought its procedures closer to the FRCP. Effective January 1, 2024, California requires parties to provide initial disclosures within 60 days of a demand, similar to federal requirements. This change aims to streamline discovery and reduce disputes over information exchange.[32]
• Colorado: Colorado’s Rules of Civil Procedure closely mirror the FRCP, emphasizing proportionality and relevance in discovery. This alignment facilitates a more efficient discovery process, ensuring that the scope of discovery is appropriate to the needs of the case.[33]
• Connecticut: Connecticut’s Practice Book incorporates many FRCP principles for civil cases, including rules on ESI and draft materials. This adoption helps maintain consistency and predictability in discovery procedures, particularly in cases involving electronic evidence.[34]
• Illinois: The Illinois Supreme Court Rules reflect key FRCP discovery concepts, especially concerning electronic communications and expert witness disclosures. This alignment ensures that parties have clear guidelines on the exchange of electronic information and the disclosure of expert testimony.[35]

While these states demonstrate significant alignment, each state includes nuances and adaptations to suit local judicial preferences and statutory requirements. Practitioners should verify the specific rules applicable to their cases.[36]

While these states have adopted principles similar to the FRCP, each maintains specific rules and procedures tailored to their judicial preferences and statutory requirements. For instance, California’s recent amendments introduce initial disclosure requirements that, in some aspects, are broader than the federal rules, requiring identification of documents relevant to the subject matter of the action.[37]

Conclusion

Understanding the discoverability rules in economic damage cases is critical for effective litigation. Federal rules establish a reliable framework for discovery, but navigating state-specific regulations requires a tailored approach that aligns with the unique legal and procedural nuances of each jurisdiction. Always consult with legal counsel or a legal research specialist for jurisdiction-specific advice.

[1] Source: For additional information, please refer to the Maryland Courts Website: https://www.courts.state.md.us/

[2] Source: For additional information, please refer to the Massachusetts Government Website: https://www.mass.gov/

[3] Source: For additional information, please refer to the Michigan Courts Website: https://www.courts.michigan.gov/

[4] Source: For additional information, please refer to the Minnesota Judicial Branch Website: https://www.mncourts.gov/

[5] Source: For additional information, please refer to the State of Mississippi Judiciary Website: https://courts.ms.gov/

[6] Source: For additional information, please refer to the Missouri Courts Website: https://www.courts.mo.gov/

[7] Source: For additional information, please refer to the Montana Judicial Branch Website: https://courts.mt.gov/

[8] Source: For additional information, please refer to the State of Nebraska Judicial Branch Website: https://supremecourt.nebraska.gov/

[9] Source: For additional information, please refer to the Nevada Judiciary Website: https://nvcourts.gov/

[10] Source: For additional information, please refer to the New Hampshire Judicial Branch Website: https://www.courts.nh.gov/

[11] Source: For additional information, please refer to the New Jersey Courts Website: https://www.njcourts.gov/

[12] Source: For additional information, please refer to the New Mexico Courts Website: https://nmcourts.gov/

[13] Source: For additional information, please refer to the New York Courts Website: https://www.nycourts.gov/

[14] Source: For additional information, please refer to the North Carolina Judicial Branch Website: https://www.nccourts.gov/

[15] Source: For additional information, please refer to the State of North Dakota Courts Website: https://www.ndcourts.gov/

[16] Source: For additional information, please refer to the Supreme Court of Ohio & the Ohio Judicial System Website: https://www.supremecourt.ohio.gov/

[17] Source: For additional information, please refer to the Oklahoma Supreme Court Website: https://www.oscn.net/v4/

[18] Source: For additional information, please refer to the Oregon Judicial Department Website: https://www.courts.oregon.gov/Pages/default.aspx

[19] Source: For additional information, please refer to the Unified Judicial System of Pennsylvania Website: https://www.courts.oregon.gov/Pages/default.aspx

[20] Source: For additional information, please refer to the Rhode Island Judiciary Website: https://www.courts.ri.gov/Pages/default.aspx

[21] Source: For additional information, please refer to the South Carolina Judicial Branch Website: https://www.sccourts.org/

[22] Source: For additional information, please refer to the South Dakota Unified Judicial System Website: https://ujs.sd.gov/

[23] Source: For additional information, please refer to the Tennessee Courts Website: https://www.tncourts.gov/

[24] Source: For additional information, please refer to the Texas Judicial Branch Website: https://www.txcourts.gov/

[25] Source: For additional information, please refer to the Utah State Courts Website: https://www.utcourts.gov/

[26] Source: For additional information, please refer to the Vermont Judiciary Website: https://www.vermontjudiciary.org/

[27] Source: For additional information, please refer to the Virginia’s Judicial System Website: https://www.vacourts.gov/

[28] Source: For additional information, please refer to the Washington Courts Website: https://www.courts.wa.gov/

[29] Source: For additional information, please refer to the West Virigina Judiciary Website: https://www.courtswv.gov/

[30] Source: For additional information, please refer to the Wisconsin Court System Website: https://www.wicourts.gov/

[31] Source: For additional information, please refer to the Wyoming Judicial Branch Website: https://www.courts.state.wy.us/

[32] Source: For additional information, please refer to the Bremer Whyte Article entitled California Makes Big Changes to the Discovery Act: https://bremerwhyte.com/news-thought-leadership/california-makes-big-changes-to-the-discovery-act/?utm_source=chatgpt.com%C2%A0

[33] Source: For additional information, please refer to the KLD Discovery Article entitled Civil Procedure Rules in State Court (Part 2): https://www.kldiscovery.com/blog/50-states-civil-procedure-rules-state-court-part-2?utm_source=chatgpt.com

[34] Source: For additional information, please refer to the 2025 Connecticut Practice Book: https://www.jud.ct.gov/Publications/PracticeBook/PB.pdf

[35] Source: For additional information, please refer to the Illinois Supreme Court Rule 201 General Discovery Provisions: https://casetext.com/rule/illinois-court-rules/illinois-supreme-court-rules/article-ii-rules-on-civil-proceedings-in-the-trial-court/part-e-discovery-requests-for-admission-and-pretrial-procedure/rule-201-general-discovery-provisions?utm_source=chatgpt.com

[36] Source: For additional information, please refer to the DLA Piper Article entitled California Adopts Broad Initial Disclosure Rule: https://www.dlapiper.com/en-us/insights/publications/2023/11/california-adopts-broad-initial-disclosure-rule?utm_source=chatgpt.com

[37] Source: For additional information, please refer to the DLA Piper Article entitled California Adopts Broad Initial Disclosure Rule: https://www.dlapiper.com/en-us/insights/publications/2023/11/california-adopts-broad-initial-disclosure-rule?utm_source=chatgpt.com

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Michael D. Pakter, CPA, CFF, CGMA, CFE, CVA, MAFF, CA, CIRA, CDBV, has more than 45 years of experience in forensic accounting, investigations, and litigation services, including more than 25 years of experience in economic damages and business valuations. State, federal, and bankruptcy courts have recognized him as an expert in forensic accounting, economic damages, business valuation, alter ego, marital dissolution, and bankruptcy core proceedings.

Mr. Pakter can be contacted at (773) 671-1950 or by e-mail to mpakter@litcpa.com.

Miranda Kishel, MBA, CVA, CBEC, MAFF, MSTCA, a Manager at Gould & Pakter Associates, LLC, supports the completion of business valuations, business calculations, forensic accounting, economic damages, and asset tracing engagements, focusing on in-depth financial analysis including modeling, forecasting, research, and report preparation. Her previous experience lies in small business consulting, commercial lending, accounting, real estate development, and economic development.

Ms. Kishel can be contacted at (218) 404-4877 or by e-mail to mkishel@litcpa.com.