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Arreguin-Leon v. Hadco Construction, 2018 UT App 225 (Dec. 13, 2018)

Dec 13, 2018

The district court allowed an expert witness to provide opinions regarding causation of an injury despite the fact that the expert had not disclosed this opinion in his deposition.  The court of appeals reversed and remanded, holding that when an expert has been locked into his opinions in a deposition—by such questions as “do you have any other opinions that you expect to offer at trial”—the expert is not allowed to offer additional undisclosed opinions at trial, just as an expert who provides a report would be limited to opinions disclosed in her report.