State v. Nieto
Supreme Court of Colorado
1Opinion of the CourtJustice Scott
Section 13-20-602, 5 C.R.S. (1999), requires a plaintiff to file a certificate of review prior to initiating a civil action for “damages ... based upon the alleged professional negligence of ... a licensed professional.” The certificate of review certifies that a plaintiff has consulted “a person who has expertise in the area of the alleged negligent conduct” and that the claims made in the complaint “do not lack substantial justification.” § 13-20-602(l)(a), (3)(a)(I) & (II).
In Nieto v. State, 952 P.2d 834 (Colo.App.1997), the Colorado Court of Appeals held that plaintiff Arthur Moses Nieto…
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