either a
"traceable chain of causation" based upon general scientific
principles or a "probable causal relationship" between Dr. Marvelli's
surgical technique and Alston's injuries. Baird, 991 S.W.2d at 922; Bradley,
879 S.W.2d at 953-54. Specifically, Alston's burden was to establish through
expert testimony that there was a reasonable medical probability that Dr.
Marvelli's alleged negligence in performing the implantation procedures was a
substantial factor in bringing about the loss of her eye and without which the
harm would not have occurred. Alston's expert witness as to causation, Dr.
Jaffe, is an ophthalmologist specializing in cataract and lens implant surgery
in Miami, Florida since 1947. Dr. Jaffe testified by deposition, based on his
review of Dr. Marvelli's deposition and medical records and the medical records
of Alston's subsequent treating physicians. At the conclusion of Dr. Jaffe's
direct examination, he summarized his opinionsthe loss of Alston's eye was Dr. Marvelli's approach
by entering from the superior position in the first surgery. That approach was
beneath the standard of care and increased the likelihood of dislocation of the
lens.
In Dr. Jaffe's opinion, Dr. Marvelli also breached the standard of care by
placing the haptic over or near the iridectomy opening. If the lens had been
placed horizontally, Dr. Jaffe said, the lens would have been over solid iris
and, in reasonable medical probability, would not have dislocated in either the
first or the second surgery. In his opinion, if the first implant had been
inserted temporally and positioned horizontally, it was extremely unlikely that
the events that followed would have occurred.
Placing the lens as Dr. Jaffe assumed Dr. Marvelli did, over the iridectomy
or even nearby, Dr. Jaffe said, "set up