Earlier tortfeasors, such as the car driver that hit the plaintiff before the doctor negligently treated his injuries. Ancillary Services, such as orderlies, technicians, medical students, janitors, aides, clerks, or administrative staff. This might also include improperly performed administrative functions, such as an HMO failing to authorize a procedure deemed necessary by their own specialist, or failing to maintain safe staffing levels. If the judge let's you mention the cap, stress it in summation. If he won't let you mention it, stress the financial losses.
None are available if there was a general verdict.
And they must be requested before entry of judgment, or they should be denied. Require security equal to unpaid portion of judgment.