In Espinosa v. Little Co. of Mary Hospital (1995) 31 Cal.App.4th 1304, the appellate court reversed a nonsuit in a medical malpractice case because the plaintiff produced expert evidence indicating there were three separate causes of a baby's brain injury (two attributable to the defendants and one attributable to the mother's use of medication early in the pregnancy), all of which the expert testified were substantial and contributory to the injury. (Id. at pp. 1316-1317, 1321.) In Espinosa, the expert testified to direct causal effect. (Espinosa, supra, at p. 1320.) The Espinosa court concluded the plaintiff is not required to apportion damages among multiple causes. "It is only necessary that a plaintiff demonstrate that the negligence of the defendant was a substantial factor in causing the claimed injury." (Id. at p. 1321.)