This decision reverses a summary judgment for the defendant in a medical malpractice case. It holds that the defendant did not satisfy its initial summary judgment burden because the expert witness declaration which was the centerpiece of its motion failed to state reasons and a factual basis for the conclusion that the defendant had conformed to the applicable professional standard of care. However, the trial court did not abuse its discretion in denying plaintiff’s motion to amend the complaint. She filed in response to defendant’s summary judgment motion, three years into the case and a few months before the scheduled trial. It would have added one new claim about informed consent which she had known about for some time, and a wholly new claim about different injuries suffered from a later operation by different doctors, thus injecting wholly new issues shortly before trial.