A recent order from the Northern District of California in Edwards Lifesciences Corp. v. Meril Life Sciences Pvt. Ltd., No. 19-cv-06593 (Jan. 27, 2022) ("Edwards"), provides guidance regarding the ability (or inability) to use a prior Daubert ruling to discredit an expert witness at trial when such a ruling arose within the context of a different case. In addition, the order highlights a pitfall that can arise when an opposing party produces deficient damages-related discovery but is not pressed to supplement its discovery through a motion to compel.
Edwards Lifesciences Corporation ("ELC") filed a motion in limine in which it sought to exclude at trial any reference to a prior Daubert order concerning ECL's damages expert that was issued by Judge Alsup in a separate action (the "Alsup Order"). Meril Life Sciences ("Meril") opposed, arguing that the Alsup Order is "highly probative" for impeachment, and to establish both bias and the limited...
