[brief] Plaintiff’s Experts Did No Work to Offer Reliable and Factually-Supported Specific-Causation Opinions.  [ISSUE WAS RAISED (Da0785; Da0816; Da0846)]**  When an expert wants to offer an opinion that one of a number of potential causes of an injury is the actual cause, the expert must have a reliable basis to both ‘rule in’ each potential cause and ‘rule out’ everything other than what the expert opines is the actual cause.  Such a differential diagnosis, if properly performed, can be an accepted method to establish specific causation.  *Magistrini*, 180 F. Supp. 2d at 609.  Here, however, Plaintiff’s experts did nothing—no testing, research, or scientific or medical analysis—to ‘rule in’ the purported silicone-particulate defect as a potential cause of Plaintiff’s eye inflammation, tractional retinal detachment, and vision loss.  They also did nothing—no testing, research, or scientific or medical analysis—to ‘rule out’ the many alternatives they agree are likely causes of Plaintiff’s eye inflammation and retinal detachment absent a silicone particulate, including: her chronic eye disease; her frequent intravitreal injections, eye surgeries, and intraocular procedures; dislocation of the Retisert®; and her continued smoking that exacerbated her uveitis (chronic eye inflammation).  Instead, Plaintiff’s experts merely assumed specific causation based on temporal proximity of her injuries to exposure to a product from a recalled lot.  But, as explained, the law rejects the assumption of causation based only on temporal proximity and the fact of a recall—particularly where, as here, the record evidence reveals a host of material differences between this Ozurdex® treatment and Plaintiff’s prior treatments that could have caused her injuries independent of any purported silicone particulate.  The Supreme Court rejects claims like these, where Plaintiff’s experts fail to reliably apply a methodology to rule out alternate causes, leaving nothing but speculation and guesswork as a basis for their specific-causation opinions.  E.g., Davis, 219 N.J. at 401; Germann, 55 N.J. at 208 (where evidence “shows a number of possible causes, only one of which” makes defendant liable, “the issue of the [defendant’s] responsibility cannot be submitted to the jury for determination.  To do so would be to authorize a decision on the basis of conjecture and speculation. ”); Jakubowski, 42 N.J. at 183 (insufficient evidence of causation where expert “failed to exclude other possible causes”); see also Nicholson, 2018 WL 3614355, at *5 (“[C]ourts should not send a case to the jury if the nature of the evidence would not allow them to determine the probable cause of the plaintiff’s injury without guess or speculation. ”).  Left only with bare conclusions unsupported by any reliable methodology applied to the facts in the case, Plaintiff’s experts’ specific-causation opinions are subject to the ‘net opinion’ rule and are inadmissible.  E.g., Murray v. Consolidated Rail Corp., 2023 WL 2193825, at *5-6 (N.J. Super. Ct. App. Div. Feb. 24, 2023) (holding expert’s specific-causation opinion was inadmissible “net opinion,” where opinion was based on assumptions and speculation and expert could not explain why he attributed the cause to one of many potential causes); In re Phenylpropanolamine (PPA), 2003 WL 22417238, at *25 (“[A]n expert opinion…based on the expert’s bare conclusions which are unsupported by factual evidence, are subject to the net opinion rule. ”).  CONCLUSION