Limprasert v. Pam Specialty Hosp. of Las Vegas LLC

Summary

The court held that Limprasert's claims arose from professional negligence because the alleged injury resulted from health-care services rendered during a professional relationship. It rejected the common-knowledge exception for distinguishing ordinary from professional negligence, but held that Limprasert's expert declaration satisfied the statutory affidavit requirement because it was incorporated by reference, executed before filing, and its authenticity and date were not contested. The court therefore reversed the dismissal and remanded for further proceedings.