n as free expert rule o Rule 803(18) Learned Treatises (free expert rule Experts often rely on learned treatises, or written works on a subject by another expert in the area. To be admissible, a learned treatise must be published in writing as a periodical, pamphlet, or treatise. o Alternatively, if published, it is theoretically reliable enough to come into evidence Rule 803(18) is the "free expert rule"-as a hearsay exception, the learned treatise may be read but not admitted into evidence. o Most experts dont have personal knowledge learned most things in school. Allowed to testify to this info because you either heard it or read it. Fact witnesses can be subpoened (made to testify and dont have to pay them); expert witnesses must be paid. The learned treatise is a substitute for live expert testimony.