From a personal injury defence perspective, albeit troubling, these cases are highly instructive. They clearly signal that defence counsel cannot ignore the need to exercise great caution when selecting an expert and particularly the need to identify and weigh any potential risk of disqualification based on bias. These cases suggest that, before retaining an expert, defence counsel must take extra care to search reported decisions for any potentially troublesome comments about the expert and interview the expert to obtain a full history of their past retainers, and how much of their income is earned from providing defence medical-legal reports. Only armed with this critical information, can defence counsel be able to assess the risk of disqualification and properly advise their clients of that risk.