[brief] Plaintiff’s expert [...] was deposed over two days, October 20, and November 24, 2021.  (Pa0027 and Pa0239).  During the initial day of his deposition, Balgowan conceded that he was not relying on any of the following sources of information in support of his opinion that [...], as the Project’s resident engineer, had an affirmative obligation to identify pre-existing roadway defects: • [...]’s contractual obligations; • Any standards promulgated for [...] projects; • The contents of any Standard or Special Provisions associated with [...] projects; • Any ethical standards applicable to the professional engineering community; or • Any regulatory authority, statute or case law.  Balgowan further conceded that his report does not discuss the standard of care generally or define the standard of care as requiring [...] to affirmatively identify pre-existing roadway defects.  (Pa0155 – Pa0157 at 129:23-131:4).  With further regard to the standard of care, Balgowan also acknowledged that the content of his report does not distinguish between the Project-related responsibilities of [...] and the other defendants, including the general contractor [...], as related to the identification of pre-existing roadway defects.  (Pa0157; Pa0158; Pa0163; and Pa0164 at p. 131:25-132:6; 137:25-138:21).  When pushed for support for his opinion that [...], as the resident engineer, had an affirmative obligation to identify pre-existing roadway defects, Balgowan testified that he would supply written authority in advance of the second day of his deposition.  (Pa0162 and Pa0163 at 136:3-137:19).  With respect to causation, Balgowan acknowledged that he could not testify to a reasonable degree of engineering certainty that the road widening project exacerbated a previously existing roadway condition. (Pa0190 and Pa0191 at 164:20-165:13).  Balgowan admitted that he is not an expert in the field of accident reconstruction.  (Pa0086; Pa0201; and Pa0216 at 60:22; 175:1-4; 175:15-17; and 190:10-20).  Balgowan also acknowledged that he possesses no information memorializing any prior accidents in the alleged area of plaintiff’s accident.  (Pa0074 – Pa0080 at 48:22-54:9).  Balgowan recognized that he did not perform any calculations concerning the physical forces associated with the accident.  (Pa0064 at 38:22-25).  Balgowan conceded that he never inspected plaintiff’s motorcycle following the accident.  (Pa0065 and Pa0066 at 39:6-40:22).  Finally, Balgowan explicitly testified that his opinion a dangerous roadway condition caused plaintiff’s accident is predicated upon his understanding that an abrupt 2” change in roadway elevation existed at the location of plaintiff’s accident involving no tapering of the roadway surface.  (Pa0186 and Pa0187 at 160:25-161:18).  By way of follow-up to the initial day of Balgowan’s deposition, [...] directed an email to plaintiff’s counsel articulating document demands associated with the initial day of Balgowan’s deposition testimony.  (Pa1858).  The referenced November 4th email specifically requested Balgowan’s production of any and all documents supporting his opinion that [...] as the resident engineer had a proactive duty to identify pre-existing roadway defects.  (Pa1858).  Second Day of Balgowan’s Deposition