Garrison v. Choh

The plaintiff, Judy Garrison, individually and as independent administrator of the estate of Betty Garrison, deceased, filed two medical malpractice actions, subsequently consolidated, against the named defendants. On the eve of trial, defendant Douglas Travis, M.D., Betty’s primary care physician, filed a motion in limine seeking to exclude all evidence pertaining to his treatment of Betty prior to July 30, 1991, arguing that the plaintiffs amended complaint did not reference such conduct. (The health professional’s report appended to the attorney’s affidavit attached to the amended…