Full opinion text
ORDER ON MOTIONS TO EXCLUDE EXPERT TESTIMONY C. ASHLEY ROYAL, District Judge. Plaintiff, Jimmie Bowers, brings this action pursuant to the Federal Employers’ Liability Act (FELA) seeking damages for back and neck injuries he sustained while employed by Defendants, Norfolk Southern Corporation, Norfolk Southern Railway Company, and Central Georgia Railroad Company (hereinafter referred to collectively as “Norfolk Southern” or “Defendants”). On September 24-25, 2002, while working as an engineer on a locomotive traveling overnight from Savannah, Georgia, to Macon, Georgia, Plaintiff allegedly suffered acute injuries to his back and neck. Plaintiff attributes his injuries to two sources: the excessive vibration of the locomotive in which he was traveling and the defective engineer’s seat on' which he sat during the five-hour journey. In his Complaint, Plaintiff alleges, inter alia, that Defendants negligently failed to properly maintain, inspect, and repair both the locomotive and the seat, and failed to provide him with a locomotive that worked properly and safely. Following the close of discovery, the parties filed multiple motions in limine. Through these motions, the parties seek to exclude the testimony of various expert witnesses for failure to satisfy the requirements of Rule 702 of the Federal Rules of Evidence, as well as ■ the standards set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993). Defendants filed four motions in limine, seeking to exclude the testimony of Dr. Arthur War-dell, an orthopaedist who performed an independent medical examination of Plaintiff; Dr. David Miller, an orthopaedic surgeon who operated on Plaintiffs lower back; Dr. Roy Baker, a neurosurgeon who treated Plaintiff; and Michael J.- O’Brien, a safety inspector who examined the allegedly defective engineer’s seat. Plaintiff, in turn, filed two motions in limine, seeking to exclude the testimony of. Robert Larson, a mechanical engineer who performed a vibration study of the locomotive and seat; and John L. Trimble, Ph.D., a biomechanical engineer who Defendants hired to evaluate the biomechanical and physiological aspects of Plaintiffs claims. In preparing to rule on the motions, the Court held a status conference with the attorneys and offered them the opportunity to have a hearing to present evidence. Neither side wanted a hearing. The Court then reviewed the depositions and affidavits of each of the experts, their curricula vitae, and their expert reports, where available in the record. The Court also reviewed ' Plaintiffs deposition and his medical records, the deposition of Michael Solesbee, the ISO standards used to measure locomotive vibration, and the various articles relied upon by Larson and Trimble in forming their opinions. After conducting an extensive review of the record, the Court held a second conference call with the attorneys to make sure that it had a proper understanding of the record. The parties confirmed that the Court did. Having reviewed the record, together with the relevant case law, the Court concludes that the parties’ motions should be GRANTED in part and DENIED in part. BACKGROUND INFORMATION In September 2002, Plaintiff worked for Defendants as a railroad engineer. At the time, Plaintiff was 57 years old, stood five feet nine inches ‘tall, and weighed 215 pounds. (PL Dep. 4:7-11, 25:14-15.) He lived in Savannah, Georgia, with his wife and spent his free time reading, exercising, walking, and performing home repair and improvement work. (PI. Dep. 10:2-24.) Plaintiff began his career with Norfolk Southern in 1970, working first as a switchman, then rising through the ranks to become a locomotive engineer in 1976. (Pl. Dep. 41:3-10.) From 1976 through 1985, Plaintiff traveled various routes throughout Middle Georgia, working as a railroad engineer. In 1985, he received a regular assignment to travel the route from Savannah to Macon. (Pl. Dep. 41:15-24.) He continued to travel the Savannah-to-Macon route until September 25, 2002, when he allegedly suffered the injuries claimed in this lawsuit. A. The September 25, 2002 Incident On the evening of September 24, 2002, Plaintiff reported to the Mason Rail Yard, located just outside of Savannah, Georgia, for his routine run from Savannah to Macon. He arrived at work at approximately 6:00 or 7:00 p.m., performed a pre-depar-ture inspection of the locomotive and equipment, and prepared for the trip from Savannah to Macon. (Pl. Dep. 43:23-25, 45:20-46:16.) Approximately two to four hours into his trip, Plaintiff experienced acute pain in his lower back, tingling in his lower legs and feet, and numbness in his right arm and hand. (Pl. Dep. 50-51, 62 & Exh. 2.) As he continued on his trip, Plaintiffs pain increased until it began “shooting up and down his back into his neck.” (Pl. Dep. 62:23-63:2 & Exh. 2.) By the time he arrived in Macon on the morning of September 25, Plaintiffs pain was severe enough to compel him to go to the local emergency room. Plaintiff has been unable to identify specifically the cause of his injuries. (Pl. Dep. 60.) However, he claims that, to his best recollection of that day, the locomotive vibrated excessively, which caused his cab seat to move laterally, “shak[ing][him] back and forth.” (Pl. Dep. 59-50.) Plaintiff additionally alleges that the cab seat lacked adequate padding. (Pl. Dep. 55, 60, 72:11-17.) Plaintiff believes that these two defects together caused his low back and neck injuries. When Plaintiff arrived in Macon, a Norfolk Southern employee met him at the rail yard and transported him to the Coliseum Medical Center for treatment. (Pl. Dep. 65:15-67:2.) There, the emergency room physician took x-rays, administered a steroid injection, and gave Plaintiff some pain pills. (Pl. Dep. 79.) Plaintiff claims that, after reviewing his x-rays, the emergency room physician diagnosed a bulging disk in his lower back and degenerative disc disease in his neck. (Pl. Dep. 94:8-9.) Later that day, Plaintiff returned to Savannah, where, over the several months that followed, he received extensive medical treatment. B. Plaintiffs Medical History Plaintiffs neck problems began long before the September 25, 2002 incident, and Plaintiff believes that, to some degree, the 2002 incident aggravated his pre-existing neck pain. (Pl. Dep. 106:6-20.) Plaintiff first sought treatment for his neck problems on October 29, 1998, with Dr. Roy Baker, a board-certified neurosurgeon in Savannah. (Baker Dep. 3:17-4:12.) During his October 29 visit, Plaintiff complained of pain in his right shoulder, arm, and neck. (Baker Dep. 4:15-21.) He told Dr. Baker that he had never before experienced any problems with his cervical spine. (Baker Dep. 4:21.) At no time during his treatment with Dr. Baker did Plaintiff mention any lower back or leg problems. Dr. Baker initially diagnosed cervical spondylosis, a condition characterized by degenerative and arthritic problems in the neck. (Baker Dep. 4-5.) Dr. Baker also noted moderate nerve compression on the right side of Plaintiffs neck. (Baker Dep. 4-5.) Dr. Baker recommended a cervical myleogram, a diagnostic procedure, to investigate Plaintiffs complaints. The my-leogram, performed on November 19, 1998, showed that Plaintiff had multiple level osteophytes and bone spurs on both the right and left sides of his cervical spine. After considering the results of the myleogram, Dr. Baker hoped that Plaintiff could avoid surgery, but thought that Plaintiff might eventually require a multilevel cervical discectomy and fusion. (Baker Dep. 6.) Dr. Baker saw Plaintiff again on November 24, 1998. On this visit, the two discussed treatment options. Plaintiff chose the physical therapy option, and Dr. Baker referred him to a physical therapist. (Baker Dep. 6-7.) The physical therapist released Plaintiff on January 12, 1999. (Baker Dep. 21.) On September 25, 2002, the day of the alleged injury, and approximately four years after he had first treated with Dr. Baker, Plaintiff went to the Coliseum Medical Center Emergency Department in Macon. The medical report of that visit shows under “HPI” (history of present illness) that Plaintiff complained of sharp and dull pains in his cervical and thoracic spine of moderate severity. Under the “Timing” section of the HPI, Plaintiff gave a medical history of the complaints beginning, “PTA” (prior to admission)— “30 days ago.” (Wardell Dep. Exh. 6.) In other words, Plaintiff gave a medical history of his lumbar and cervical problems beginning thirty days before sitting in the allegedly faulty locomotive seat. Upon returning to Savannah, Plaintiff saw Dr. Henry Deriso, an orthopaedist. (PI. Dep. 94:24-95:6.) After examining Plaintiff, Dr. Deriso advised him that he could return to work. (PL Dep. 97:9-11.) Plaintiff disagreed, and chose instead to obtain a second opinion from Dr. Baker. (Pl. Dep. 97.) Plaintiff returned to Dr. Baker on October 25, 2002. During his visit, Plaintiff complained of pain in his neck, lower back, and legs. He attributed his injuries to the September 25, 2002 incident, stating that he “had been sitting in a firm chair with not much padding,” and explaining that “he got so shook up sitting there he developed a lot of back pain and neck pain.” (Baker Dep. 8-9.) Dr. Baker examined Plaintiffs cervical and lumbar spine and concluded that Plaintiffs neurological exam was normal. Dr. Baker did not find any significant neurological problems other than Plaintiffs complaints. (Baker Dep. 10-11.) Because Plaintiff complained of pain shooting down his arms and legs, Dr. Baker recommended a second myleogram, which Plaintiff underwent shortly thereafter. (Baker Dep. 12-13.) Dr. Baker next saw Plaintiff on November 4, 2002. Dr. Baker reviewed Plaintiffs myleograms and concluded that Plaintiffs lumbar myleogram did not look too bad. Plaintiffs cervical myleogram, however, showed bilateral nerve root compression of the C4-5 and C5-6 vertebrae, as well as slight compression of the C6-7 vertebra. (Baker Dep. 13.) In addition, the myleo-gram revealed a large bar of bone spurs spanning those three levels of Plaintiffs cervical spine. (Baker Dep. 12-13.) Dr. Baker saw no evidence of an acute herniated disc. (Baker Dep. 23.) Dr. Baker further testified that the changes he noted on the myleograms typically do not develop in a matter of weeks. (Baker Dep. 25.) Dr. Baker concluded that, in his opinion, lumbar surgery would not help Plaintiff. (Baker Dep. 26.) Plaintiff never returned to Dr. Baker following that visit. Instead, Plaintiff saw two other physicians, both located in Rocky Mount, North Carolina. On January 8, 2003, Plaintiff traveled from Savannah to Rocky Mount to see Dr. Gilbert Whitmer, an orthopae-dist. Plaintiffs attorney referred him to Dr. Whitmer. (PI. Dep. 111:19-25; Miller Dep. 7:20-8:6.) During his office visit with Dr. Whitmer, Plaintiff told him that he worked as a railroad engineer and that, during a five-hour train trip, he started developing back and neck pain that gradually worsened during the trip. Plaintiff told Dr. Whit-mer that the seat in the locomotive caused his problems, describing it as a wooden seat with very little padding. (Miller Dep. 8:6-17 & Exh. 6.) Dr. Whitmer diagnosed Plaintiff with cervical spondylitis, lumbar degenerative disc disease, and spinal sten-osis. (Miller Dep. Exh. 6.) Dr. Whitmer then referred Plaintiff to his partner, Dr. David Miller, for treatment. Plaintiff returned to Rocky Mount on January 28, 2003, to meet with Dr. Miller, an orthopaedist who specializes in spinal surgery. (Miller Dep. 7:3-14.) Plaintiff recounted a similar medical history to Dr. Miller, describing neck and back problems arising during and after a five-hour train trip. Dr. Miller concluded that Plaintiff showed signs of disk and joint problems at the L4-5 level and spondylosis, or “wear and tear” changes, at the L5-S1 level. (Miller Dep. 12:10-16.) Dr. Miller also noted “wear and tear” changes in Plaintiffs cervical spine. (Miller Dep. 12:14-16.) Dr. Miller opined that Plaintiffs neck and back problems resulted from the work-related injury to his lumbar spine that occurred on September 25, 2002. (Miller Dep. 12:22-25.) Following his examination of Plaintiff, Dr. Miller ordered discography studies on Plaintiffs lumbar spine. These studies were performed in Savannah to save Plaintiff the trip to North Carolina. Dr. Miller then saw Plaintiff again on February 25, 2003, to review the results of these studies and discuss treatment options with Plaintiff. Based on the studies, Dr. Miller believed that Plaintiff had significant problems at the L4-5 and L5-S1 levels. (Miller Dep. 14:9-16:6.) Accordingly, Dr. Miller recommended that Plaintiff undergo spinal surgery and Plaintiff agreed. (Miller Dep. 16:12-19.) On April 9, 2003, Dr. Miller performed extensive surgery on Plaintiffs spine at a hospital in Tarboro, North Carolina. He discharged Plaintiff from the hospital three days later, on April 12, 2003. (Miller Dep. 39:17 & Exh. 2.) Following his discharge, Plaintiff returned to North Carolina for several post-surgical follow-up visits with Dr. Miller. Plaintiff last saw Dr. Miller on November 4, 2003. Dr. Miller’s final diagnosis was that Plaintiff suffered a L4-5 and L5-S1 disk injury and spondylosis at L5-S1. (Miller Dep. 32:17-18.) Dr. Miller assigned Plaintiff a twenty percent “permanent partial impairment” (disability) rating. (Miller Dep. 30:19-21.) Dr. Miller based Plaintiffs disability rating on the fact that he had undergone a two-level spinal fusion. (Miller Dep. 30:24-31:6.) Plaintiff agrees that his health has improved since his surgery; however, he claims that he still cannot perform many of his normal daily activities. (PI. Dep. 128:8-10.) Plaintiff further claims that his back problems continue to prevent him from working as a railroad engineer, though he admits that, given the proper training, he may be able to perform other work, such as clerical work, for Norfolk Southern. (PI. Dep. 129:11-131:3.) LEGAL STANDARD This case turns on the issues of causation and damages. The six expert witnesses who are the subjects of the six motions in limine filed in this case offer opinions on these very issues. The admissibility of expert testimony is governed by Rule 702 of the Federal Rules of Evidence. Rule 702 provides: If scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education, may testify thereto in the form of an opinion or otherwise, if (1) the testimony is based upon sufficient facts or data, (2) the testimony is the product of reliable principles and methods, and (3) the witness has applied the principles and methods reliably to the facts of the case. Fed.R.Evid. 702. Simply stated, under Rule 702, relevant expert testimony is admissible only if the trial court finds that: (1) the expert is qualified to testify about the matters he intends to address; (2) the methodology used by the expert to reach his conclusions is sufficiently reliable; and (3) the expert’s testimony will assist the trier of fact, through the application of scientific, technical, or specialized expertise, to understand the evidence or determine a fact in issue. McCorvey v. Baxter Healthcare Corp., 298 F.3d 1253, 1257 (11th Cir.2002) (citing Maiz v. Virani, 253 F.3d 641, 664 (11th Cir.2001)); J & V Dev., Inc. v. Athens-Clarke County, 387 F.Supp.2d 1214, 1223 (M.D.Ga.2005). As the Supreme Court noted in Daubert v. Merrell Dow Pharmaceuticals, Inc., Rule 702 imposes a duty on trial courts to act as “gatekeepers” to insure that speculative and unreliable opinions do not reach the jury. 509 U.S. 579, 589 n. 7, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993); McClain v. Metabolife Int’l, Inc., 401 F.3d 1233, 1237 (11th Cir.2005). The overall objective of the gatekeeping requirement is to make certain that expert witnesses employ in the courtroom the “same level of intellectual rigor that characterizes the practice of an expert in the relevant field.” Kumho Tire Co. v. Carmichael, 526 U.S. 137, 152, 119 S.Ct. 1167, 143 L.Ed.2d 238 (1999); Goebel v. Denver & Rio Grande W. R.R. Co., 346 F.3d 987, 992 (10th Cir.2003). The court’s gatekeeping role is especially significant, since “the expert’s opinion can be both powerful and quite misleading because of the difficulty in evaluating it.” United States v. Frazier, 387 F.3d 1244, 1260 (11th Cir.2004). To fulfill its role as a gatekeeper, the trial court must determine whether the expert has the requisite qualifications to offer the opinions he gives. Poulis-Minott v. Smith, 388 F.3d 354, 359 (1st Cir. 2004); Frazier, 387 F.3d at 1260-61. The trial court must also “conduct an exacting analysis of the foundations of expert opinions to ensure they meet the standards for admissibility under Rule 702.” Finally, the court must “ensure the relevancy of expert testimony,” meaning that it must determine whether the testimony will assist the trier of fact. Daubert, 509 U.S. at 591, 113 S.Ct. 2786. The court’s performance of its gatekeeping role is informed by Rule 104(a), which teaches that preliminary questions are committed to the court’s determination, and which further empowers courts, in making such determinations, to rely on evidence without being constrained by the rules of evidence. Id. at 593, 113 S.Ct. 2786. In sum, in acting as a gatekeeper, the court is responsible for “keepfing] unreliable and irrelevant information from the jury,” because of its “inability to assist in factual determinations, its potential to create confusion, and its lack of probative value.” Allison v. McGhan Med. Corp., 184 F.3d 1300, 1311—12 (11th Cir.1999). Though Daubert involved scientific experts, the Supreme Court has since made it clear that the strictures of Rule 702 and Daubert apply with equal force to nonscientific expert witnesses. See Kumho Tire, 526 U.S. at 147, 119 S.Ct. 1167. In all cases, the proponent of the expert witness bears the burden of establishing that the expert’s testimony satisfies the qualification, reliability, and helpfulness requirements of Rule 702 and Daubert. McClain, 401 F.3d at 1238 & n. 2; Frazier, 387 F.3d at 1260. Importantly, “[a]ny step that renders the analysis unreliable renders the expert’s testimony inadmissible.” Goebel, 346 F.3d at 992 (quoting Mitchell v. Gencorp, Inc., 165 F.3d 778, 782 (10th Cir.1999)) (internal alterations omitted). Beginning with the qualification requirement, the Eleventh Circuit has advised that “experts may be qualified in various ways.” Frazier, 387 F.3d at 1260-61. Certainly, an expert’s scientific training or education may provide one means by which an expert may qualify to give certain testimony; however, experience in a particular field may also qualify an expert to offer an opinion on a particular matter. Id. Indeed, “experts come in various shapes and sizes” and, consequently, “there is no mechanical checklist for measuring whether an expert is qualified to offer opinion evidence in a particular field.” Santos v. Posadas De Puerto Rico Assocs., 452 F.3d 59, 63 (1st Cir.2006). In all cases, the salient inquiry is whether the expert has the requisite skill, experience, training, and education to offer the testimony he intends to introduce. Poulis-Minott, 388 F.3d at 359. With respect to the reliability requirement, the Eleventh Circuit counsels courts to assess “whether the reasoning or methodology underlying the testimony is ... valid and whether that reasoning or methodology properly can be applied to the facts at issue.” Frazier, 387 F.3d at 1262. This inquiry must focus “solely on the principles and methodology [of the experts], not on the conclusions that they generate.” Daubert, 509 U.S. at 595, 113 S.Ct. 2786; Goebel, 346 F.3d at 992. Daubert supplies a list of four non-exclusive factors that courts may consider in evaluating the reliability of an expert’s testimony: (1) testability; (2) error rate; (3) peer review and publication; and (4) general acceptance. 509 U.S. at 593-95, 113 S.Ct. 2786; J & V Dev., Inc., 387 F.Supp.2d at 1223. These four factors apply most comfortably in cases involving scientific testimony, but may offer little help in other cases, particularly those involving non-scientific experts. See Kumho Tire, 526 U.S. at 150-52, 119 S.Ct. 1167. Accordingly, the factors are merely illustrative, rather than exhaustive, and “considerable leeway” is conferred upon the trial court in deciding which tests or factors to use to assess the reliability of an expert’s methodology. Id. An additional list of factors is found in the advisory committee notes to Rule 702. These factors are: (1) Whether the expert is proposing to testify about matters growing naturally and directly out of research he has conducted independent of the litigation, or whether he has developed his opinion expressly for purposes of testifying; (2) Whether the expert has unjustifiably extrapolated from an accepted premise to an unfounded conclusion; (3) Whether the expert has adequately accounted for obvious alternative explanations; (4) Whether the expert is being as careful as he would be in his regular professional work outside his paid litigation consulting; (5) Whether the field of expertise claimed by the expert is known to reach reliable results for the type of opinion the expert would give. Fed.R.Evid. 702, advisory committee’s note (2000 amends.). Like the four Dau-bert factors, these factors do not comprise a definitive checklist, nor is any single factor dispositive of reliability; instead the tests articulated in the advisory committee notes merely illustrate the issues a court may consider in evaluating an expert’s testimony. See id. The final requirement for admissibility of expert testimony is that it be helpful to the trier of fact. Expert testimony is helpful to the trier of fact “if it concerns matters that are beyond the understanding of the average lay person.” Frazier, 387 F.3d at 1262. “[EJxpert testimony generally will not help the trier of fact when it offers nothing more than what lawyers for the parties can argue in closing arguments.” Id. Nor does expert testimony help the trier of fact if it fails to “fit” with the facts of the case. McDowell v. Brown, 392 F.3d 1283, 1298 (11th Cir.2004). Expert testimony lacks “fit” when “a large analytical leap must be made between the facts and the opinion.” See Gen. Elec. Co. v. Joiner, 522 U.S. 136, 147, 118 S.Ct. 512, 139 L.Ed.2d 508 (1997) (“A court may conclude that there is simply too great an analytical gap between the data and the opinion proffered.”). Thus, testimony that is otherwise reliable may nevertheless be excluded if it does not have “sufficient bearing on the issue at hand to warrant a determination that it [is ‘helpful’ to the trier of fact].” Bitler v. A.O. Smith Corp., 391 F.3d 1114, 1121 (10th Cir.2004). At all times when scrutinizing the reliability and relevance of expert testimony, a court must remain mindful of the delicate balance between its role as a gatekeeper and the jury’s role as the ultimate fact-finder. A district court’s “gatekeeper role ... is not intended to supplant the adversary system or the role of the jury.” Allison, 184 F.3d at 1311-12. “Vigorous cross-examination, presentation of contrary evidence, and careful instruction on the burden of proof are traditional and appropriate means of attacking shaky but admissible evidence.” Daubert, 509 U.S. at 596, 113 S.Ct. 2786. A court may not “evaluate the credibility of opposing experts” or the “persuasiveness of competing scientific studies”; instead, its duty is limited to “ensur[ing] that the fact-finder weighs only sound and reliable evidence.” Quiet Tech. DC-8, Inc. v. HurelDubois UK, Ltd., 326 F.3d 1333, 1341 (11th Cir.2003); Frazier, 387 F.3d at 1272. In close cases involving testimony of debatable reliability, this Court chooses to err in favor of admitting the testimony and allowing opposing counsel to draw out any weaknesses through cross-examination. As a final matter, the Court’s application of Rule 702 and Daubert in this case is not altered in any way by the substantive law governing Plaintiffs claims. While this is a FELA case, to which a relaxed standard of causation applies, “the standard of causation under FELA and the standards for admission of expert testimony under the Federal Rules of Evidence are distinct issues and do not affect one another.” Claar v. Burlington N. R.R. Co., 29 F.3d 499, 503 (9th Cir.1994). Thus, the fact that FELA employs a relaxed standard of causation “does [not] mean that in FELA cases courts must allow expert testimony that in other contexts would be inadmissible.” Id. Rather, the admission of expert testimony is controlled — even in FELA cases — by the Federal Rules of Evidence and Daubert. Id. DISCUSSION With these principles in mind, the Court now turns to the merits of each motion, beginning with the Defendants’ four motions in limine. A. Defendants’ Motions in Limine 1. Arthur Wardell, M.D. Defendants have moved to exclude the opinions of Arthur W. Wardell, M.D., an orthopaedist who performed an “independent” medical examination of Plaintiff at Plaintiffs request. Dr. Wardell opines that a vibrating locomotive seat caused a permanent aggravation of Plaintiffs underlying degenerative neck and back condition during a five-hour train trip on September 25, 2002. (Wardell Dep. 16, 30, May 26, 2005.) Dr. Wardell is a causation and damages witness for Plaintiff. He did not treat Plaintiff, and he did not examine him until after Dr. Miller performed extensive surgery on Plaintiffs lumbar spine. Defendants attack Dr. Wardell’s testimony by arguing both, that he lacks the requisite qualifications and that his opinions lack a reliable scientific basis. The Court will consider only Defendants’ objection to the reliability of Dr. Wardell’s causation opinions, which mainly concern the etiology of Plaintiffs injuries. Plaintiff primarily defends the reliability of Dr. Warden’s opinions by arguing that he used a “differential diagnosis” approach — an approach which, according to Plaintiff, is widely accepted as reliable. Before discussing the problems with the “differential diagnosis” approach in this case, the Court will test Dr. Wardell’s methodology using the four factors discussed in Daubert and the five factors outlined in the Rule 702 advisory committee notes. At the outset, the Court notes that Plaintiffs pre-injury medical history, combined with his claim that an unknown amount of vibration caused his injuries, present an unusually complex causation issue. As explained below, the complexity of the causation issue in this case drives the Court’s conclusions about the reliability of Dr. Wardell’s methodology. Before discussing the reliability of Dr. Wardell’s opinions, however, the Court will briefly recount Plaintiffs dealings with Dr. War-dell. Dr. Wardell first saw Plaintiff on September 27, 2004, on referral from Plaintiffs counsel. Plaintiff gave Dr. Wardell the same history that he had previously recited to many of his other treating physicians — he stated that he had developed progressive pain in his neck and back while working as an engineer on a long train trip on September 24-25, 2002. Plaintiff related the onset of his pain to the bouncing and rattling associated with the engineer’s seat. He further explained that the locomotive seat lacked significant shock absorption and adequate padding. (Wardell Dep. 7-10.) Based primarily on this history, Dr. Wardell testified that “after completing the differential diagnosis, my opinion was that the cause of that permanent aggravation was the trip on the seat of September 24, 2002.” (Wardell Dep. 17.) Dr. War-dell said in his report dated October 8, 2004: “I think that the exposure to vibration was a significant factor leading to Mr. Bowers [sic] premature degenerative disc disease and cervical spondylosis.” (War-dell Dep. Ex. 2.) Significantly, Dr. Wardell concluded that Plaintiff had degenerative arthritis and degenerative disc disease in his back and neck before the September 25, 2002 incident. Indeed, all of the experts seem to agree on this point. Dr. Wardell also testified that the aggravation of Plaintiffs pre-existing condition “could have been caused by any source of trauma. It could have been caused by a lifting injury. It could have been caused by a fall. It could have been caused by twisting wrong. It could have been caused by sports.” (War-dell Dep. 17.) He therefore concedes that any type of trauma could have exacerbated Plaintiffs pre-existing back and neck condition. (Wardell Dep. 61.) With this background in mind, the Court will now scrutinize Dr. Wardell’s testimony using the four Daubert factors and the five advisory committee note factors mentioned above. In so doing, the Court will “conduct an exacting analysis of the foundations of [Dr. Wardell’s] opinions to ensure they meet the standards of reliability under Rule 702.” United States v. Frazier, 387 F.3d 1244, 1260 (11th Cir.2004) (citing McCorvey v. Baxter Healthcare Corp., 298 F.3d 1253, 1257 (11th Cir.2002)) (emphasis in original). a. Reliability of Dr. Wardell’s Testimony Simply stated, Dr. Wardell cannot satisfy any of the Daubert factors: he has not demonstrated that his causation opinions are testable; he has not offered any error rate for his opinions; he has not shown any evidence that his opinions have been peer reviewed or that he used a peer-reviewed source to reach his opinions; and, finally, he has not shown the general acceptance of his opinions. Consequently, his opinions fail all four of the Daubert factors. Presumably the Court could stop here, rule out Dr. Wardell’s unreliable opinions, and stand on firm ground within the abuse of discretion standard and the flexibility accorded to trial courts in testing expert opinions. See United States v. Brown, 415 F.3d 1257, 1265-66 (11th Cir.2005) (discussing the abuse of discretion standard and the ‘considerable leeway’ conferred upon trial courts in evaluating the admissibility of expert testimony). But the Court will move to the next level of analysis. The advisory committee notes under Rule 702 offer five additional factors for testing expert opinions. The first factor asks “whether the expert is proposing to testify about matters growing naturally and directly out of research he has conducted independent of the litigation, or whether he has developed his opinions expressly for purposes of testifying.” For three important reasons, Dr. Wardell fails this test. First, Plaintiffs attorney sent Plaintiff to see Dr. Wardell in Suffolk, Virginia, some 460 miles away from Plaintiffs home in Savannah. Dr. Wardell did not see Plaintiff to treat him, but only to build Plaintiffs damages case; therefore, he does not qualify as a “treating physician.” Moreover, although Dr. Wardell is a board-certified orthopaedist, his interest is sports medicine, and he does not perform back surgery. Accordingly, Dr. Wardell did not see Plaintiff independent of this litigation; he saw him solely for this litigation. Second, Dr. Wardell admitted that, beginning as far back as 1980, he has seen hundreds of patients on referral from attorneys. In the course of a year, he sees approximately sixty such patients, and virtually one hundred per cent of the time, those patients are plaintiffs in lawsuits. Third, Plaintiffs counsel has sent other clients to Dr. Wardell, and he admitted that he saw Plaintiff strictly for purposes of this lawsuit. (Wardell Dep. 38.) He further admitted that he does not normally treat patients from Georgia and agreed that many good orthopedic surgeons do practice in Georgia. (Wardell Dep. 78-81.) Armed with these facts and Dr. War-dell’s history, the Court can easily identify him as a hired gun expert and simultaneously conclude that he cannot satisfy the first factor — the “independence” factor— under the advisory committee notes. Dr. Warden’s testimony likewise fails to satisfy the second factor under the advisory committee notes, which asks “whether the expert has unjustifiably extrapolated from an accepted premise to an unfounded conclusion.” The term “accepted premise” is commonly understood to include either a premise that is generally accepted by the medical or scientific community, or one that is found in a recognized text, treatise, or other reliable source. In the present case, Plaintiff has not made the Court aware of any “accepted premise” upon which Dr. Wardell’s opinions are based. Perhaps one “accepted premise” underlying Dr. Wardell’s opinions is that vibration can cause injury. Even if this premise is an accepted one, it is too vague to have any meaning for a Daubert analysis, especially in light of Dr. Wardell’s concession that not all vibration can cause harm. (Wardell Dep. 45.) Absent from this vague premise is any specific information about the amount of vibration that is harmful to an individual, the length of time over which such harm normally occurs, and the nature of the resulting harm. Further absent from Dr. Wardell’s testimony is any reference to the level of vibration Plaintiff endured and the length of time over which he endured it. Dr. Wardell has offered no quantification, no parameters, no percentages, no numbers — nothing except dogmatic, but vague, opinions. The Court cannot rely on Dr. Wardell’s ipse dixit to judge the reliability of his conclusion that vibration can cause back problems, and more specifically, that the vibration of Defendants’ locomotive seat caused Plaintiffs back problems. Kumho Tire, 526 U.S. at 157, 119 S.Ct. 1167. This is especially true because Dr. Wardell agreed that “all of us are exposed to vibration every day.” (Wardell Dep. 45.) Such vague and imprecise opinions are often excluded by trial courts and their exclusion is regularly affirmed by the Eleventh Circuit. E.g., McDowell v. Brown, 392 F.3d 1283, 1299, 1301 (11th Cir.2004) (characterizing expert’s testimony as “too vague” and noting that “[a] mere guess that earlier treatment would either have improved [the plaintiffs] condition or rendered it the same simply fails the tests for expert opinion”); Frazier, 387 F.3d at 1266 (characterizing the expert’s testimony as “imprecise” and “unspecific,” and noting that, in light of such imprecision, the jury “could not readily determine whether the ‘expectation’ [alluded to by the expert] was a virtual certainty, a strong probability, a possibility more likely than not, or perhaps even just a possibility”). Not only do such opinions lack reliability, they also fail to assist the trier of fact in any meaningful way. See McDowell, 392 F.3d at 1299; Frazier, 387 F.3d at 1266. This failure provides an additional reason for their exclusion. Plaintiff further offends the second factor by making an “unjustifiable extrapolation” from an additional, unstated premise underlying Dr. Wardell’s opinions. Plaintiff presupposes that, because an orthopae-dist can usually testify about the cause of a plaintiffs injuries based primarily on his history, Dr. Wardell should be permitted to testify about the cause of Plaintiffs condition in this case. The Court does not accept this premise in this case because of the unusual complexity of Plaintiffs injuries — namely, his pre-injury medical history of degenerative disk disease, his thirty days of pre-existing symptoms, and his claim that an unknown amount of vibration caused his injuries. Plaintiff has failed to convince the Court that by examining a patient, taking his history, and reviewing all of the studies and radiographs, an or-thopaedist can always reach a valid causation opinion. Plaintiff certainly cannot establish that in this case. For the same reason, he cannot prove that Dr. Wardell satisfies the second factor under the advisory committee notes. The third factor under the advisory committee notes asks “whether the expert has adequately accounted for obvious alternative explanations.” Dr. Wardell’s methodology also fails this test. Plaintiff gave a medical history at the Coliseum Medical Center Emergency Department on September 25, 2002, the day of the alleged incident. In it, he described how his cervical and lumbar complaints began thirty days earlier — thirty days before his train trip on the vibrating seat. He stated that his lumbar and cervical pains were both sharp and dull, that the severity of them was moderate, and that the pains were intermittent in nature. (Wardell Dep. Ex. 6.) Thus, when he sought treatment in the emergency room following the September 25, 2002 incident, Plaintiff was experiencing moderately severe pain, and had been suffering such pain before that time for approximately one month. Dr. Wardell fails to adequately address this important information, which bears directly on both the source and onset of Plaintiffs lumbar pain. He offers no explanation for the cause of the thirty days of intermittent lumbar and cervical pain that preceded the pain that the vibration allegedly caused. He likewise offers no explanation for when the pain from one cause stopped and pain from the vibrating seat began, or how to distinguish between the two. Indeed, he is unable to do so because he concedes “that there was no one time injury here.” (Wardell Dep. 53.) In sum, Dr. Warden’s testimony makes it difficult to determine whether Plaintiff suffered a new injury as a result of the September 25, 2002 incident or just one more bout of the intermittent pain that began thirty days before. Dr. Wardell’s failure to adequately account for this obvious alternative explanation creates a fatal analytical gap in his testimony. Continuing in this same vein of “excluding other causes,” Dr. Wardell testified that when Plaintiff described the seat’s thin padding and minimal shock absorption, “[h]e noted that about fifty per cent of his time was spent on such seats, and that the seats had been designed the same way since [the] early 1990s.” (Wardell Dep. 10.) Nothing in the record reflects that sitting on this seat or a seat like this one for fifty percent of the time since the early 1990s caused Plaintiff any problems. The Court is left to ponder how the ride of September 24, 2002, differed from all of the other rides Plaintiff had taken over the preceding decade. Dr. Wardell offers no answer, leaving yet another analytical gap in his opinions. Finally, on the “excluding other causes” factor, Plaintiffs lumbar complaints fall into a category of complaints with a very high background risk in the general population. See McClain v. Metabolife Int’l, Inc., 401 F.3d 1233, 1243-44 (11th Cir.2005) (discussing background risks). As Dr. Wardell admits, approximately eighty percent of the general population experiences back problems at one time or another. (Wardell Dep. 63.) This is the background risk for back problems. Yet, an extremely small number of this eighty percent work as locomotive engineers, and an even smaller number sit on vibrating seats in locomotives. Nonetheless, eighty percent of the population still develops back pain. So, whether he worked as an engineer or not, and whether he sat on a vibrating seat or not, Plaintiff had a very high risk of having lumbar pain caused by something other than a vibrating seat. This reality further dilutes.the reliability of Dr. Warden’s conclusions. But the dilution does not stop here. According to Dr. Wardell, everyone is exposed to vibration every day. (Wardell Dep. 45.) This means that Plaintiff was exposed to vibration on a daily basis in the thirty-day period preceding the train trip. With dilution diluting dilution, the Court is left with scientific backwash. Dr. Wardell, therefore, fails the third factor. The fourth factor under the advisory committee notes asks “whether the expert is being as careful as he would be in his regular professional work outside his paid litigation consulting.” As with the three previous factors, Dr. Wardell’s methodology fails this factor. When cross-examined about the vibration standards and studies that might apply to the work place, Dr. Wardell conceded that he knew nothing about those standards or studies. (War-dell Dep. 42, 46-51.) Instead, Dr. Wardell protested that the studies did not involve a fifty-nine-year-old man like Plaintiff. These protestations amount to a lame evasion of legitimate cross-examination. In fact, from his answers on cross-examination, the Court infers that Dr. Wardell did not want to be confused with the scientific facts about the effect of vibration on the human body. By crafting an opinion with little regard for the scientific standards and studies on vibration, Dr. Wardell has failed to exercise the same care- as he would in his work outside his paid litigation consulting. As above, Dr. Wardell’s conduct is consistent with that of a hired gun expert. Notwithstanding Dr. Wardell’s admitted failure to familiarize himself with the various vibration standards and studies, the Court is confident that Dr. Wardell subscribes to and reads the orthopedic literature, and otherwise stays abreast of developments in orthopedics. (Wardell Dep. 50.) Nevertheless, in reaching his causation opinions, he did nothing to research that literature. For testifying about causation in routine orthopedic cases, this step is unnecessary; but, as the Court explained at the outset of this Order, this is not a routine case. Moreover, it appears from the record that Dr. Wardell simply took Plaintiffs word for what happened and adopted that explanation as his own opinion on causation. Certainly, Dr. Wardell examined Plaintiff and reviewed his medical records and radiographic studies, but he admitted that he based his opinion primarily on Plaintiffs history. (Wardell Dep. 11-12, 52.) This raises the question of the value of Plaintiffs history. The Court can easily conclude that Plaintiffs history made little difference in his treatment. Dr. Miller saw Plaintiff, examined him and took his history, but he did not operate on him at that time. If Plaintiffs history were so important, Dr. Miller could have rolled Plaintiff into the operating room in Tarboro, North Carolina, as soon as he learned that vibration injured his back. But Dr. Miller did not do that. He sent Plaintiff back to Savannah to undergo discography studies, and only after seeing those studies did he operate on Plaintiffs spine. So Plaintiffs history was not the key to treating Plaintiffs back problems. Yet, Plaintiffs radiology studies, however important they may have been in diagnosing and treating Plaintiffs back problems, do not prove causation. What Dr. Wardell saw on those films did not show what caused Plaintiffs injuries. If they had, Dr. Wardell would have readily identified the pathognomonic proof and summarily ended this causation dispute. Even more importantly, no evidence shows that, had the examinations, studies, and radiographs all been performed before Plaintiff boarded the train on September 24, 2002, there would have been any difference in his clinical condition or x-ray findings. Plaintiffs medical records show that he had degenerative disk disease before the September 25, 2002 incident and that he was symptomatic. Plaintiff has offered no proof to dispute this. In fact, Dr. War-dell testified that x-rays and MRIs taken of Plaintiffs neck and back after the train trip showed no evidence of any acute injury. (Wardell Dep. 53.) In light of this, the Court cannot conclude that Dr. War-dell was as careful in formulating his causation opinions as he would have been in his regular work as an orthopaedist. One final problem with the level of care exercised by Dr. Wardell is his admitted lack of analysis in reaching his conclusions. Defense counsel asked Dr. Wardell this question: “You agree with me, sir, that you employed absolutely no scientific analysis or methodology to come to the conclusion that vibration aggravated [Plaintiffs] back and neck problems.” He responded: “I did not.” Yet, he conceded that Plaintiffs condition required more analysis than determining the cause of a simple injury such as a broken arm. (Wardell Dep. 53.) One would presume that, in light of this concession, Dr. Wardell would have taken greater care to familiarize himself with the literature and consider the various possible causes of Plaintiffs condition before formulating his opinions regarding the cause of Plaintiffs injuries. But he did not analyze this case any further than taking Plaintiffs word for what caused his harm. Dr. Wardell therefore fails the fourth factor. The fifth factor under the advisory committee notes asks “whether the field of expertise claimed by the expert is known to reach reliable results for the type of opinion the expert would give.” The Court will recast the question for this case: Is it enough, even if Dr. Wardell exercised the care he usually exercises in practicing orthopedics, for him to reach reliable opinions about the effect of vibration on Plaintiffs back, in light of Plaintiffs pre-existing condition and Dr. War-dell’s ignorance, both about the amount of vibration Plaintiff sustained and about the level of vibration that will cause a back injury? The complexity of the question implies the answer: no. Plaintiff, who has the burden of proof, offered the Court no proof on this question. Again, this is not the typical case where an orthopaedist can adopt a patient’s history as his causation opinion. A few examples of typical eases include: the brittle-boned octogenarian who falls in the kitchen and breaks her hip; the defensive end who has his knee crushed by a 330-pound offense tackle and suffers an anterior cruciate tear; the woman who falls in a grocery store and suffers a Colles’ fracture of her wrist; and the unbelted passenger who is ejected during a car wreck, lands on his head in a cotton field, and suffers a compression fracture of his cervical vertebra. In these typical cases, an orthopaedist legitimately can adopt a patient’s history as his causation opinion, since the patient has sustained a common injury in a way that it commonly occurs. This case is easily distinguishable from the typical cases just described-it involves a patient with preexisting lumbar and cervical problems and a thirty-day intermittent exacerbation of those problems, who claims that vibration from a faulty locomotive seat caused his harm. The complexity of the causation issues in this case underscores the need for Dr. Wardell to have done more than simply adopt Plaintiffs history as his causation opinion. Because he failed to do anything more, Dr. Wardell fails the fifth factor under the advisory committee notes. In light of all of the problems outlined above, it appears that Dr. Wardell based his causation testimony on a temporal relationship, not on a scientific method. In doing so, he has blundered into the post hoc ergo propter hoc fallacy. “The post hoc ergo propter hoc fallacy assumes causality from temporal sequence. It literally means ‘after this because of this.’ It is called a fallacy because it makes a false assumption based on the false inference that a temporal relationship proves a causal relationship.” McClain, 401 F.3d at 1243 (citing Black’s Law Dictionary 1186 (7th ed.1999)). This fallacy is one that ancient logicians exposed several millennia ago, but that still causes the naive to stumble. Opinions based on little, if anything, more than this time-dishonored fallacy should not go to the jury. The fact that Dr. Wardell has earned an M.D. degree does not necessarily authorize him to come to court and testify when he does not base his methods on valid science. Flores v. Johnson, 210 F.3d 456, 464 (5th Cir.2000). He cannot use orthopedic alchemy to turn Plaintiffs complaints into gold. The trial court has “considerable leeway in deciding in a particular case how to go about determining whether particular expert testimony is reliable.” Kumho Tire, 526 U.S. at 152, 119 S.Ct. 1167. In this case, whether applying the Daubert factors alone, the Rule 702 advisory committee note factors alone, or by combining them together, Plaintiff simply cannot prove by a preponderance of the evidence that Dr. Wardell employed a reliable methodology to reach his opinions. b. The Differential Diagnosis Method Plaintiff primarily defends the reliability of Dr. Warden’s opinions by claiming that Dr. Wardell used the “differential diagnosis” method to reach his causation opinions. Plaintiffs argument lacks merit for two main reasons. First, as discussed in greater detail below, the Court questions whether Dr. Wardell actually used the differential diagnosis method in the way that a treating physician diagnoses his patient’s disease or injury. Second, simply claiming that an expert used the “differential diagnosis” method is not some incantation that opens the Daubert gate to allow an expert’s opinions to be admitted at trial. Indeed, it can easily amount to nothing more than medico-legal sophistry used in an attempt to avoid the Court’s reliability analysis. This is especially true where, as here, the expert essentially stamps his badge of expertise on a medico-legal history given by a lawyer-referred plaintiff. At any rate, Plaintiff cannot use the “differential diagnosis” argument to trump Dr. War-dell’s total failure to pass the tests recommended in Daubert and the Rule 702 advisory committee notes. Nonetheless, the Court will address Plaintiffs points concerning the differential diagnosis method. On the first point, the Court finds that Dr. Wardell did not perform a “differential diagnosis” on Plaintiff. Dorland’s Illustrated Medical Dictionary defines “differential diagnosis” as “the determination of which one of two or more diseases or conditions a patient is suffering from, by systematically comparing and contrasting their clinical findings.” Dorland’s Illustrated Medical Dictionary 490 (29th ed.2000). Similarly, Stedman’s Medical Dictionary defines it as “the determination of which of two or more diseases with similar symptoms is the one from which the patient is suffering, by a systematic comparison and contrasting of the clinical findings.” Stedman’s Medical Dictionary 417 (26th ed.1995), cited in Clausen v. M/V NEW CARISSA, 339 F.3d 1049, 1058 (9th Cir.2003). These definitions focus on diagnosing the disease, not on determining the etiology or cause of the disease. They describe a physician treating his patient, not an expert building a plaintiffs special damages. Dr. Wardell’s approach does not comply with this definition because he did not try to diagnose and treat Plaintiff. He examined him to give a medico-legal opinion about causation and the extent of Plaintiffs damages. Dr. Wardell himself agreed that determining cause is different from making a correct diagnosis. (War-dell Dep. 91.) The term “differential etiology” more aptly describes Dr. Wardell’s approach in this case. This term is “used on occasion by expert witnesses or courts to describe the investigation and reasoning that leads to the determination of external causation, sometimes more specifically described by the witness or court as a process of identifying external causes by a process of elimination.” McClain, 401 F.3d at 1252 (citing Mary Sue Henifin et al., Reference Guide on Medical Testimony, in Reference Manual on Scientific Evidence 439, 481 (Federal Judicial Center, 2d ed.2000)). It is too easy to gloss over these two definitions and conclude that they amount to a distinction without a difference. Indeed, courts in various circuits have admitted expert testimony supposedly based on the “differential diagnosis” method, when, in reality, the testimony is based on the “differential etiology” method. The distinction is more than semantic; it involves an important difference. The difference arises from what is at stake in the two distinct methods and what that difference implies about the likely reliability of the expert’s opinions. When a doctor develops his differential diagnosis in treating a patient, two factors strongly insure that the doctor will follow a reliable methodology to diagnose the patient’s condition. First, if he misdiagnoses the patient’s condition, the patient may die. And second, if he misdiagnoses the patient’s condition and the patient dies, then the patient’s family will sue the doctor for medical malpractice. By contrast, when an expert witness uses the differential etiology approach to testify in court to support a litigant’s case, he has very little at stake. He renders his opinion, and then gets paid, often quite handsomely. The plaintiff is at no risk of harm, and the expert will not get sued for malpractice. The differential diagnosis method has an inherent reliability; the differential etiology method does not. This conclusion does not suggest that the differential etiology approach has no merit. It simply means that courts, when dealing with matters of reliability, should consider opinions based on the differential etiology method with more caution. It also means that courts should not conflate the two definitions. Setting aside the problem of twisted terms, the Court will address Plaintiffs argument that Dr. Wardell’s so-called “differential diagnosis” was a reliable method by which he formed his causation opinions. Plaintiff claims that “[i]t is well-settled that a differential diagnosis is an accepted scientific method to determine causation.” (Pl.’s Mem. in Opp’n 9.) Plaintiffs argument is not an accurate statement of the law because using the “differential diagnosis” method does not trump the reliability requirement. Rather, opinions based on a differential diagnosis are admissible only if the trial court determines that the expert reliably applied the differential diagnosis method. See, e.g., Goebel v. Denver & Rio Grande W. R.R. Co., 346 F.3d 987, 999 (10th Cir.2003); see also Westberry v. Gislaved Gummi AB, 178 F.3d 257, 263 (4th Cir.1999) (“[A] reliable differential diagnosis provides a valid foundation for an expert opinion.”) (emphasis supplied); Clausen, 339 F.3d at 1057 (“[F]ederal courts, generally speaking, have recognized that a properly conducted differential diagnosis is admissible under Daubert.”) (emphasis supplied). Thus, in evaluating the reliability of an opinion based on a differential diagnosis, courts look at the substance of the expert’s analysis, rather than just the label. See, e.g., Clausen, 339 F.3d at 1057-58 (advising courts to evaluate whether an expert, in conducting a differential diagnosis, has: (1) insured that the potential cause can in fact cause the injury; (2) taken care to consider other hypotheses that might otherwise explain a plaintiffs condition; and (3) taken care to explain why “the proffered alternative cause was ruled out.”); see also Heller v. Shaw Indus., Inc., 167 F.3d 146, 155 (3d Cir.1999) (explaining that the differential diagnosis method “ ‘consists of a testable hypothesis,’ has been peer reviewed, contains standards for controlling its operation, is generally accepted, and is used outside of the judicial context.”) (citing In re Paoli R.R. Yard PCB Litig., 35 F.3d 717, 742 n. 8 (3d Cir.1994)). The Eleventh Circuit itself has recognized both the importance of a properly-conducted differential diagnosis and the need to look past the labels given to an expert’s method to ensure that the opinions he offers are reliable. In McClain, the Eleventh Circuit stated: Under certain circumstances, circumstances that ensure reliability, [the differential diagnosis] approach may offer an important component of a valid methodology. This approach, however, will usually not overcome the fundamental failure of laying a scientific groundwork for the general toxicity of the drug and that it can cause the harm a plaintiff suffered. 401 F.3d at 1252. Two important points flow from McClain into the stream of the Court’s analysis of Dr. Warden’s method. First, the expert’s approach — whether a differential diagnosis or a differential etiology — • must be reliable. As already explained, Dr. Wardell’s method, whatever the label, was not reliable. Second, the expert’s approach must include in its causes one that is recognized to cause the harm that a plaintiff suffered. The Court accepts that under certain circumstances and at certain levels, vibration can injure someone. However, according to Dr. Wardell, we are all subject to vibration in our daily lives. (Wardell Dep. 45.) As previously discussed, Dr. Wardell has no idea of the level of vibration known to cause harm, nor does he know whether Plaintiff was subjected to such a level. These failures undermine the reliability of Dr. Warden’s method. In concluding its analysis of Dr. War-dell’s “differential diagnosis” approach, the Court will quote an excerpt from a Fifth Circuit case that, while factually different from this case, aptly describes Dr. War-dell’s work in this case: Dr. Johnson has admitted that Viterbo’s symptoms could have numerous causes and, without support save Viterbo’s oral history, simply picks the cause that is most advantageous to his claim. Indeed, Dr. Johnson’s testimony is no more than Viterbo’s testimony dressed up and sanctified as the opinion of an expert. Without more than credentials and a subjective opinion, an expert’s testimony that ‘it is so’ is not admissible. Viterbo v. Dow Chem. Co., 826 F.2d 420, 424 (5th Cir.1987). The court in Viterbo excluded the expert’s causation testimony. Dr. Wardell’s causation opinions suffer the same fate. After this lengthy analysis of Plaintiffs “differential diagnosis” argument, the Court will fire one last round into the corpse of Dr. Wardell’s opinions. Proffered expert testimony generally will not help the trier of fact when it offers nothing more than what lawyers for the parties can argue in closing arguments. Frazier, 387 F.3d at 1262-63; Dukes v. Georgia, 428 F.Supp.2d 1298, 1816 (N.D.Ga.2006). In the present case, Plaintiffs lawyers can argue that vibration from the seat caused Plaintiffs injuries, because that is what Plaintiff said caused them, without the aid of Dr. Wardell’s testimony. Dr. Wardell has merely adopted Plaintiffs history to help Plaintiff with his lawsuit. His opinions, therefore, add nothing to Plaintiffs case apart from what Plaintiffs lawyers already can argue to the jury. Finally, as the Supreme Court recognized in Daubert, “expert testimony can be powerful and quite misleading.” 509 U.S. at 595, 113 S.Ct. 2786. When Dr. Wardell simply anoints Plaintiffs medical history with his testimony, the nimbus of his M.D. degree and his board-certification in ortho-paedics will likely have an impact on the jury, far surpassing the merit of his weak and unreliable opinions. See Frazier, 387 F.3d at 1260 (“The district court’s [gatek-eeping] role is especially significant since the expert’s opinion ‘can be both powerful and misleading because of the difficulty in evaluating it.’ ”) (quoting Daubert, 509 U.S. at 595, 113 S.Ct. 2786). For the same reasons, Dr. Wardell’s opinions are subject to exclusion under Rule 403. See id. at 1263 (“Because of the powerful and potentially misleading effect of expert evidence, sometimes expert opinions that otherwise meet the admissibility requirements may still be excluded by applying Rule 403.”). The Court finds that Dr. Wardell based his causation opinions on nothing more than a shady simulacrum of professional judgment and reliable methodology. Because Plaintiff has not demonstrated by a preponderance of the evidence that Dr. Wardell employed a reliable methodology to reach his opinions, his opinions are subject to exclusion under Rule 702 and Daubert. Defendants’ Motion to Exclude Dr. Wardell is therefore GRANTED. 2. David Miller, M.D. Defendants next move to exclude the testimony of David A. Mi