CBM Eng'rs, Inc. v. Tellepsen Builders, L.P
In CBM Eng'rs, Inc. v. Tellepsen Builders, L.P., 403 S.W.3d 339, 345 (Tex. App.--Houston 1st Dist. 2013, pet denied), the Court held that a certificate of merit does not "need to recite the applicable standard of care and how it was allegedly violated in order to provide an adequate factual basis for the identification of professional errors." Id.
As the Court noted, a certificate of merit is "filed early in the litigation, before discovery and before other dispositive motions may be available." Id. at 346.
Accordingly, the plaintiff is not required to marshal her evidence or establish every element of her claims. See id.
Instead, "Chapter 150 requires only that a licensed professional, practicing in the same area of expertise as the defendant, provide a sworn written statement certifying that the defendant's actions were negligent or erroneous and stating the factual basis for this opinion." Id.