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Christie v. Flynn
In this medical malpractice action, Kathleen Christie appeals a judgment of nonsuit entered against her on the ground she presented no expert evidence that William M. Flynn, M.D., breached the applicable standard of care. Christie contends the trial court improperly granted a defense motion in limine that precluded her from introducing the deposition testimony of one of her consulting physicians under Code of Civil Procedure[1]section 2025.620, subdivision (c)(1) on the ground he lived in Utah, more than 150 miles from court. Alternatively, she contends expert opinion was not required because the alleged malpractice was within the common knowledge of laypersons. Court affirm the judgment.

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