Separate Statement Citation

Wicks v. Antelope Valley Healthcare Dist., No. B297171 (D2d8 Jun. 1, 2020) 

Appeal of a granted summary judgment in a med-mal case. Defendant put in the declaration of an expert who testified about a lack of causation. The expert reviewed the medical records and included them with his declaration. But Defendant’s separate statement cited only the paragraphs of the declaration containing the expert’s opinions. Court here holds that was adequate under Rule of Court 3.1350(d)(3), which requires evidentiary citations in a separate statement to make “reference to the exhibit, title, page, and line numbers” of any cited evidence.

Affirmed.