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.)
Defendants, Daniel Li, D.C. and XYZ Chiropractic, Inc., hereby move this Court, in limine, for an order precluding plaintiff Anna Greene’s orthopaedic expert Hiram White, M.D. from testifying to any opinions not expressed during his deposition.
Defendants further move for the Court’s instructions on the following:
1. An instruction precluding Plaintiff’s Counsel and Plaintiff’s witnesses from conveying the jury, directly or indirectly, the facts provided in this motion without, first, obtaining permission of the Court outside the presence and hearing of the jury; and
2. An instruction precluding Plaintiff, Plaintiff’s Counsel and Plaintiff’s witnesses from making any reference to the filing of this motion.
This motion is based upon the attached memorandum of points and authorities, the pleadings and papers already on file in this matter, and on such further oral and documentary evidence that may be presented at the hearing of this motion.
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.
MEMORANDUM OF POINTS AND AUTHORITIES
INTRODUCTION
Plaintiff, Anna Greene alleges Defendant, Daniel Li, D.C, improperly performed a chiropractic adjustment to her left hip during treatment at XYZ Chiropractice, Inc., on May 25, 2007. As a result of Daniel Li , D.C.’s alleged negligence, Plaintiff alleges she suffered a medial meniscus tear to her right knee. (See Part 2 of 6.)
For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.