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Rule 1042.32.Additional and Supplemental Reports.

Adopted March 29, 2004 · Not amended since adoption · Last verified June 30, 2026

In one sentenceRule 1042.32 lets a party serve additional or supplemental expert reports without the court's permission until the court's production deadline passes, and those reports may raise new theories of liability or causation.

Full Text of Rule 1042.32

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Until a deadline set by the court for the production of expert reports has passed or unless the court has precluded such production, a party may serve additional and supplemental expert reports without leave of court. These reports may introduce new theories of liability or causation or new defenses, and may be prepared by other experts.
End

Plain-English Summary

Expert opinions can develop as a case moves forward. This rule lets a party file further or updated expert reports without asking the court first, so long as the court's deadline for producing reports has not yet run and the court has not cut off further reports.

Because a supplemental report may add a new theory of liability or causation, the rule keeps the door open for an evolving case while the court's schedule still sets the outer limit.

Frequently Asked Questions

Do I need the court's permission to file a supplemental expert report?

Not until the court's deadline for producing expert reports has passed or the court has precluded further reports.

Can a supplemental report add a new theory?

Yes. It may introduce new theories of liability or causation.

Amendment History

The provisions of this Rule 1042.32 adopted March 29, 2004, effective immediately, 34 Pa.B. 1926.

Source & verification. Rule text, the Official Note, and the amendment history are reproduced verbatim from the Pennsylvania Code, Title 231, the official compilation of rules adopted by the Supreme Court of Pennsylvania. This rule has not been amended since its adoption. Last verified June 30, 2026. · Official text
Also known as: supplemental expert reportadditional expert reportnew theory of liability