Sacramento Birth Injury Lawyer Blog

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.)

David Greene was seen and evaluated by a speech therapist, Hadley Smith, Ph.D. On two separate occasions, specifically October 29, 2002, and approximately ten months later. Additionally, plaintiff was seen and evaluated at ABC Pediatric by registered physical therapist, Cynthia Lee, P.T., P.C.S. Also on two separate occasions, specifically September 20, 2002 and about ten months later. Two videotapes were produced in conjunction with the ABC Pediatric therapy evaluations.

A number of David Greene's medical experts recommended these tests be done in order to further provide them with additional information in which to base their expert opinion. This was done. True and correct copies of each and every report by Hadley Smith, Ph.D. and Cynthia Lee, P.T. are attached hereto as Exhibits 1, 2, 3 and 4, respectively.

PLAINTIFF'S EXPERTS, STEFAN HALL, M.D., HANK WHITE, PH.D., AND SALLY JACKSON MAY PROPERLY RELY UPON AND TESTIFY REGARDING THE TEST RESULTS AND VIDEOTAPES DONE BY HADLEY SMITH, PH.D. AND CYNTHIA LEE, P.T.

Evidence Code §801 states:

For more information you are welcome to contact Sacramento personal injury lawyer, Moseley Collins.

Continue reading " Sacramento Boy Suffers Birth And Brain Injuries At Local Hospital, Part 2 of 5 " »

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.

Continue reading " Sacramento Family Files Lawsuit For Child's Birth Injuries, Part 1 of 5 " »