The following blog entry is written to illustrate a common motion filed during civil litigation. Reviewing this kind of filing should help potential plaintiffs and clients better understand how parties in personal injury cases present such issues to the court.
(Please also note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this birth and brain injury lawsuit and its proceedings.)
Plaintiff, David Greene’s, Opposition to Defendant, Robert Johnson, M.D.’s, Motion in Limine No. 10
Plaintiff, David Greene, a minor, by and through his Guardian ad Litem, Owen Greene, hereby opposes defendant, Robert Johnson, M.D.’s, Motion in Limine No. 10 for order precluding plaintiff from introducing all reports, data, opinions, etc., of speech therapist, Hadley Smith, Ph.D., and physical therapist, Cynthia Lee, P.T., and from allowing all experts from testifying and relying on their testing materials.
This Opposition is based on the attached Memorandum of Points and Authorities.
MEMORANDUM OF POINTS AND AUTHORITIES
INTRODUCTION
As a result of defendant, Robert Johnson, M.D.’s, negligence, minor child David Greene suffers from two separate and distinct injuries; a brachial plexus/ Erb’s palsy to the right upper extremity and an hypoxic Ischemic Encephalopathy resulting in residual brain injury, behavioral, cognitive and speech deficits.
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.
David Greene has been seen and evaluated by numerous doctors and physicians, including Stefan Hall, M.D., a pediatric neurologist, Hank White, Ph.D., a neuropsychologist and Sally Jackson, a life care plan specialist. (See Part 2 of 5.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.