In Elkins v. Syken, 672 So. 2d 517 (Fla. 1996), the discovery requests in the consolidated cases were directed not to the parties, but to the expert medical witnesses who had performed compulsory physical examinations (IMEs) of the plaintiffs. The discovery orders required the physicians to produce the number of IMEs performed by them in the preceding years, the amount of income and percentages of income earned from IMEs, the number of IME exams performed for insurance carriers and for defense attorneys, the identity of every person the expert had examined at the request of defense counsel, as well as all billing and payment information related to examinations and opinions rendered at the request of any insurance company or law firm. See Elkins 672 So. 2d at 519-20. The en banc court of the Third District quashed the trial court's orders, finding the requests to the defense expert physicians to be unduly burdensome, while yielding "little useful information." Syken v. Elkins, 644 So. 2d 539, 545 (Fla. 3d DCA 1994). The Court quoted with approval the Third District's observations that decisions in this field have gone too far in permitting burdensome inquiry into the financial affairs of physicians, providing information which "serves only to emphasize in unnecessary detail that which would be apparent to the jury on the simplest cross-examination: that certain doctors are consistently chosen by a particular side in personal injury cases to testify on its respective behalf." Elkins, 672 So. 2d at 521-22 (quoting Syken, 644 So. 2d at 545). The Third District set forth eight criteria to be followed in seeking financial information from an expert "in an effort to prevent the annoyance, embarrassment, oppression, undue burden, or expense, claimed on behalf of the medical experts." 672 So. 2d at 521 (quoting Syken, 644 So. 2d at 546-47) The Court subsequently adopted those criteria. See Elkins, 672 So. 2d at 522. In rejecting the argument that the information was necessary to explore the bias of the expert witness, this Court balanced the probative value of the information sought against the annoyance and embarrassment to the expert physicians caused by the discovery requests. See id. at 521-22. The Court concluded that the Third District's criteria struck a "reasonable balance between a party's need for information concerning an expert witness's potential bias and the witness's right to be free from burdensome and intrusive production requests." Id. at 522. In striking this balance, this Court observed that it is "essential" to keep in mind the purpose of discovery, which is "to eliminate the element of surprise, to encourage settlement of cases, to avoid costly litigation, and to achieve a balanced search for the truth to ensure a fair trial." Id.