California, United States of America
The following excerpt is from Ramirez v. Javahery, B292801 (Cal. App. 2020):
6. Plaintiff asserts that expert testimony is not required to establish a failure to obtain informed consent, an assertion not supported by the cases plaintiff cites. To the contrary, one of the cases on which plaintiff relies holds that the plaintiff's failure to submit an expert declaration was "fatal to [her] appeal." (Willard v. Hagemeister (1981) 121 Cal.App.3d 406, 412.)
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