Joseph Hoang v. PNK Lake Charles, LLC, et al.

Summary

The court grants Defendants’ motion in limine to exclude evidence and expert opinions concerning future medical treatment and its costs, except for one future repeat of a cervical epidural steroid injection identified in a medical report. The court holds that the plaintiff failed to comply with Federal Rule of Civil Procedure 26(a)(2)(C) by not adequately disclosing opinions concerning future surgeries or other future treatment.

Holdings

1. A party must provide a sufficiently specific summary of the facts and opinions supporting a treating physician's anticipated expert testimony under Rule 26(a)(2)(C); vague disclosures concerning future treatment do not satisfy the rule.
2. Evidence concerning future medical treatment, future cervical surgery, and the costs of such treatment was excluded at trial, except for evidence concerning one future repeat of a cervical epidural steroid injection identified in Dr. Burton's report.

Questions Presented

1. Whether Plaintiff's treating physicians could offer expert testimony or other evidence concerning future medical treatment, future cervical surgery, and the cost of such treatment when those opinions were not adequately disclosed under Federal Rule of Civil Procedure 26(a)(2)(C).
2. Whether evidence of one future repeat of a cervical epidural steroid injection identified in Dr. Burton's report should be excluded.

Disposition

other