Extract to table

AMA objects to specific paragraphs, tables, and opinions contained in the Rennick Declaration on the grounds that they fail to satisfy the requirements for admissible expert testimony under California Evidence Code sections 801 and 802, and that they must be excluded under the California Supreme Court's gatekeeping framework as articulated in Sargon Enterprises, Inc

Under Sargon, an expert opinion based on an assumption that is "contrary to the evidence" or "without evidentiary support" must be excluded

Under Sargon, expert opinion based on "speculative or conjectural factors" must be excluded

The rest period damages opinion lacks any evidentiary foundation and constitutes pure speculation that must be excluded under Sargon

The evidentiary environment is fundamentally different at these two groups of facilities, and any reliable damages model must account for that difference

The factual foundation of the opinion must be connected to the facts of the case, and where the facts vary materially across subgroups, the opinion must account for that variation or explain why it can be disregarded