In a personal injury action, can a treating physician be subpoenaed?
California, United States of America
The following excerpt is from Malabed-Verona v. Hollaway, B278154 (Cal. App. 2018):
Citing Smith v. Covell (1980) 100 Cal.App.3d 947, appellant argues that defense counsel's argument was improper because her treating physicians were "'equally available to subpoena by [respondent].'" (Italics omitted.) In Smith, the plaintiff filed an action for personal injuries she claimed were caused by a car accident. (Id. at p. 951.) At trial, two of the plaintiff's treating
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