In fact, bereft of supplication of the documentation specified in plaintiff's Request to Produce any opinions of defendant's bio-mechanical expert are mere net opinions unsupported by facts, appropriate authority or the like. As such, it is respectfully submitted that it is appropriate in this litigation to bar defendant's purported bio-mechanical expert's report and trial testimony due to non-compliance with the afore referenced discovery requests.
madamjujujive at 10:42 pm
madamjujujive at 10:42 pm



































