![]() ![]() His testimony will be based on his experience, training and expertise, as well as the Plaintiff’s medical records. Exhibit 2.ĭefendant’s Preliminary Expert Designation reveals that each of these witnesses practices in the same specialty, will testify as to the same issues, and will offer essentially the same opinions based upon essentially the same factual basis.ĭr. Exhibit 1.ĭefendant has identified two expert witnesses to rebut Plaintiff’s case on the issues of standard of care and causation, Robert Jenkins, M.D. Smith, M.D., a board-certified general surgeon who will testify on the issues of the applicable standard of care and medical causation. Plaintiff has identified a single expert witness, Dennis P. Chen negligently caused an injury to the Plaintiff’s common bile duct while attempting a laparoscopic cholecystectomy (gallbladder removal). ![]() This is a medical negligence case in which it is alleged that Dr. Defendant’s Experts Have Identical Specialties and Will Offer Identical Opinions Based Upon Identical Facts. ![]() Pursuant to Maryland Rule 5-403, Plaintiff moves to preclude this duplicative testimony because it is unfairly prejudicial, and because it will lead to “undue delay, waste of time, or needless presentation of cumulative evidence.” Argument Plaintiff, Phyllis French, by and through her counsel, hereby files Plaintiff’s First Motion In Limine to Preclude Cumulative Expert Witness Testimony.ĭefendant has named two physicians in identical specialties who will offer substantially identical opinions based upon substantially identical reasoning. Plaintiff’s Motion in Limine to Preclude Cumulative Expert Testimony IN THE CIRCUIT COURT FOR BALTIMORE CITY, MARYLAND ![]()
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