In Garza v. Tan, 849 S.W.2d 430 (Tex. App.--Corpus Christi 1993, no pet.), the appellants claimed that the appellees failed to supplement their interrogatories and that the substance of their expert's testimony was not timely produced as required under Rule 166b(6)(b). Id. at 433.
Rule 166b(6)(b) required a supplemental response to include only "the name, address and telephone number of the expert witness and the substance of the testimony concerning which the expert witness is expected to testify, as soon as is practical, but in no event less than thirty (30) days prior to the beginning of trial except on leave of court." Id. at 434.
The appellees' interrogatories included the names, addresses, and phone numbers of their expert doctors and stated that they would testify about the standard of care and medical treatment. The appellees also provided each doctor's expert reports. Id.
The Garza court held that the appellees' interrogatories and expert reports adequately disclosed the substance of their experts' testimony, and therefore, that the appellees' responses were timely. Id.