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0809 A physician examining a claimant on behalf of a workers' compensation carrier owes the claimant a duty to perform the examination in a reasonable manner to avoid injuring her; the medical malpractice statute of limitations applies to a claim that the physician breached that duty; even though conducted in preparation for litigation, a physical examination is non-communicative and, therefore, not protected by the litigation privilege of CivC 47.CitationMERO v SADOFF (Clumsy Doctor) 31 CA4 1466 [See: Felton v Schaeffer 229 CA3 229; Keene v Wiggins 69 CA3 308 ; Flowers v Torrance Memorial 8 C4 992; Rowland v Christian 69 C2 108; CCP 340, 364; CivC 47]
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