California, United States of America
The following excerpt is from Schmidt v. Universal Pain Mgmt., Inc., B276904 (Cal. App. 2018):
the motion.2 (See Garibay v. Hemmat (2008) 161 Cal.App.4th 735, 741 ["'[i]n professional malpractice cases, expert opinion testimony is required to prove or disprove that the defendant performed in accordance with the prevailing standard of care [citation], except in cases where the negligence is obvious to laymen'"].)3
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