Bohl v. Aluminum Co. of Am., Inc.

Citations

• 2020 Ohio 2824

Syllabus

Expert report Civ.R. 26 Loc.R. 21.1 separation of witnesses Evid.R. 615 office visit note hearsay medical records hospital records self-authenticating Evid.R. 902(10) R.C. 2317.422 business records exception Evid.R. 803(6) certification motion in limine failure to object leading questions. Trial court acted within its discretion in denying motion for separation of witnesses and allowing defense expert witness to read transcript of plaintiff's expert testimony where plaintiff failed to provide the defense with an expert report in advance of trial. Medical records of plaintiff's treating physician were admissible as self-authenticated business records because they were properly certified by the hospital. Trial court properly denied motion to exclude expert witness testimony where expert's testimony was consistent with opinions set forth in his expert report and addendum to the expert report.