at 9-12. This appears to be the minority view. See Sprague v. Liberty Mut. Ins. Co., 177 F.R.D. 78, 81 (D.N.H.1998) (“The majority of other courts in the country have concluded that Rule 26(a)(2)(B) reports are not required as a prerequisite to a treating physician expressing opinions as to causation, diagnosis, prognosis and extent of disability where they are based on the treatment.”) (collecting cases). The majority view recognizes that a treating or examining physician “may form an opinion about causation as a necessary part of the treatment rather than at the request of counsel, and the purposes of Rule 26 may be satisfied without a formal report.” Krischel v. Hennessy, 533 F.Supp.2d 790, 795 (N.D.Ill.2008) (citing Fielden v. CSX Transp. Inc., 482 F.3d 866, 870-71 (6th Cir.2007) (<HOLDING>)); see also Watson v. United States, 485 F.3d
holding the touchstone of determining existence of erisa plan is whether an administrative scheme is required recognizing the crawford interrogation was more formal but determining the interrogation of hammons wife was formal enough in considering that factor and determining the wifes statements were testimonial holding sba is an integral part of federal government and is not a separate legal entity holding that a formal report is not required when determining causation is an integral part of treating a patient holding that causation section of expert medical report was not eonclusory when read in context of entire report