It is worth noting that situations similar to those described in this medical malpractice case could just as easily occur at any of the healthcare facilities in the area, such as Kaiser Permanente, UC Davis Medical Center, Mercy, Methodist, or Sutter.
(Please also note: the names and locations of all parties have been changed to protect the confidentiality of the participants in this personal injury lawsuit and its proceedings.)
Plaintiff’ Anna Greene’s Opposition to Defendants’ Motion in Limine No. 5 to Exclude Plaintiff’s Expert, Ronald Hill, D.C.; Memorandum of Points And Authorities In Support Thereof.
Plaintiff submits this Opposition to Defendants’ Daniel Li and ABC Chiropractic, Inc.’s (collectively Defendants ), Motion in Limine No. 5, for an order excluding the testimony of plaintiff’s standard of care expert, Ronald Hill, D.C.
This Opposition is based on the following Memorandum of Points and Authorities, the exhibits attached hereto, and on such further argument, evidence or supplemental points and authorities as may be presented at the time of the hearing.
MEMORANDUM OF POINTS & AUTHORITIES
INTRODUCTION
CURRENT POSTURE
Plaintiff’s complaint alleges causes of action for professional negligence, battery, assault, false imprisonment, intentional infliction of emotional distress, and negligent infliction of emotional distress.
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.
Prior to trial, plaintiff intends to withdraw its causes of action for assault, false imprisonment, intentional infliction of emotional distress, and negligent infliction of emotional distress. Plaintiff also intends to dismiss defendant Daniel Li, D.C., in his individual capacity, as soon as defendants stipulate that Universal Chiropractic is responsible for the actions of Dr. Li, in the event negligence or battery is found. (See Part 2 of 7.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.