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Civil Litigation,
California Supreme Court,
California Courts of Appeal

Feb. 20, 2014

Third-party lienors discoverable in bodily injury cases

A recent decision gives guidance to tort litigants during discovery when seeking evidence of the reasonable value of medical expenses incurred. By Craig A. Roeb and David A. Weinberger

Craig A. Roeb

Partner
Chapman, Glucksman, Dean, Roeb & Barger APC

11900 W Olympic Blvd
Los Angeles , CA 90064

Email: croeb@cgdrblaw.com

Loyola Law School; Los Angeles CA

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David Weinberger

Chapman Glucksman Dean Roeb & Barger

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A recent appellate decision from the 2nd District Court of Appeal reinforces the state Supreme Court's decision in Howell v. Hamilton Meats, 52 Cal. 4th 541 (2011), by ruling that a defendant may discover a third-party lien holder's records if the records are relevant to the issue of plaintiff's alleged medical expenses. See Dodd v. Cruz, 2014 DJDAR 1530 (Feb. 5, 2014).

In Howell, the Supreme Court finally approved the holdings of both Hanif v. Housing Aut...

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