p0581 In an action for surgical malpractice, expert testimony that plaintiff's injury more probably than not resulted from improper positioning of the patient or dropping the patient, neither of which would have occurred without defendant's negligence, is too speculative to be admissible in the absence of any evidence that either of those events actually happened.CitationBUSHLING v FREMONT MEDICAL (Expert Speculation) 117 CA4 493 [See: EvC 801; Kelley v Trunk 66 CA4 519, T/AT 10/98; Hanson v Grode 76 CA4 601, T/AT 1/00; Jennings v Palomar 114 CA4 1108, P/AT 3/04]
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