What is the test for disclosing expert reports in a medical malpractice case?

California, United States of America


The following excerpt is from People v. Palacio, D064643 (Cal. App. 2015):

Section 1054.7 provides: "The disclosures required under this chapter shall be made at least 30 days prior to the trial, unless good cause is shown why a disclosure should be denied, restricted, or deferred. . . ." If the evidence or other information required to be disclosed is discovered within 30 days of trial, it must be disclosed to the other party immediately. ( 1054.7; People v. Verdugo (2010) 50 Cal.4th 263, 280.)

Under section 1054.1, subdivision (f), the term "reports" includes handwritten notes of an expert in arriving at his or her expert opinion (People v. Hajek and Vo (2014)

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