For those who litigate medical malpractice cases, it is common to encounter complicated issues involving multiple, overlapping areas of practice, specialty and subspecialty. Any individual defendant can have several experts in multiple subspecialties rendering targeted opinions. One subspecialty for causation and another for standard of care or damages. Objections are often made when questioning an expert about opinions not expressly stated in his or her report. But, objections such as these, at a discovery deposition, are baseless. As set forth below, it is incumbent on the questioning attorney to insist on a thorough examination of every opinion of the opposition expert.
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