(a) Name, address and telephone number of any witness whom the party may call at trial together with a copy of any statement of such person or if there is not such statement, a summary of the testimony the person is expected to give. However, no party shall be required to furnish any statement (written or taped) protected by the attorney-client privilege or work product rule.

(b) A description, drawing or photograph of any physical evidence which is to be presented at trial.

(c) A copy of any document or writing which is to be presented at trial.

(d) A brief summary of the qualifications of any expert witness the party may call at trial together with a report or statement of any such expert witness which sets forth the subject matter of the expert witnesses' anticipated testimony; the substance of the facts and opinions to which the expert is expected to testify, and a summary of the grounds for each opinion.

(e) A statement summarizing each contention in support of every claim or defense which the party will present at trial and a brief statement of the facts upon which the contentions are based.

(f) Offers of stipulation.

(g) A concise statement of each issue of law and each issue of fact recognized by the party.