In Edwards-Tubb v JD Wetherspoon PLC [2011] EWCA Civ 136, the Court of Appeal held that the court could not override privilege in an earlier expert’s report, but could and would normally require waiver of the privilege as a condition of granting permission to adduce evidence from a different expert.
— Read on hsfnotes.com/litigation/2011/03/22/disclosure-of-privileged-report-as-condition-of-changing-experts-2/
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