California, United States of America
The following excerpt is from Liu v. Superior Court of Cal. for L.A., B246461 (Cal. App. 2013):
standard of care; except when the alleged negligence would be obvious to a layman. (Kelley v. Trunk (1998) 66 Cal.App.4th 519, 523.) Plaintiff asserts that the expert declarations submitted by defendants were not sufficient to shift the burden.
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