concurring.
I write separately because I respectfully disagree with the analysis in the Court’s opinion. In my view the Court has greatly enlarged Maryland Rule 2-415(g) beyond its text, beyond its proper construction, and beyond the way in which the circuit courts administer the rule and in which litigators apply it. Further, the Court bases its construction primarily on policy reasons that are debatable and that encroach on the adversary system.
Maryland Rule 2-415(g) reads:
“Objections. All objections made dining a deposition shall be recorded with the testimony. An objection to the manner of taking a deposition, to the form of questions or answers, to the oath or affirmation, to the conduct of the parties, or to any other kind of error or irregularity that might be obviated or removed if objected to at the time of its occurrence is waived unless a timely objection is made during the deposition. An objection to the competency of a witness or to the competency, relevancy, or materiality of testimony is not waived by failure to make it before or during a deposition unless the ground of the objection is one that might have been obviated or removed if presented at that time.”
*259Nowhere does the rule expressly require that the ground of objection be stated for those objections that would be waived if the objection is not made.
The self-evident purpose of the rule is to expedite depositions. There is no need to object at all “unless the ground of the objection is one that might have been obviated or removed if presented at that time.” The general rule is that objections are not even required at a deposition; rather, they are deferred, to be made if and when the deposition testimony is offered in evidence in court. To add a requirement that the ground of the objection must be stated at the deposition prolongs the deposition.
Further, under the ordinary rules of construction, the meaning given part of a rule should be consistent with the rules as a whole. Rule 2—415(b) tells us that “[w]hen a deposition is taken upon oral examination, examination and cross-examination of the deponent may proceed as permitted in the trial of an action in open court.” In open court, when an objection is made to the admission of evidence “[t]he grounds for the objection need not be stated unless the court, at the request of a party or on its own initiative, so directs.” Rule 2-517(a). Thus, if one looks beyond the literal wording of Rule 2^415(g) to the larger context, one is directed to a conclusion that is contrary to that espoused by the Court today.
In 1986 the Board of Governors of the Maryland State Bar Association approved discovery guidelines, and the guidelines were approved by the Conference of Circuit Court Judges. Annotated Code of Maryland (1999), 1 Md. Rules at 171. The Maryland Discovery Guidelines were revised by the Litigation Section of the Maryland State Bar Association in February 1990. Id. Although the Maryland Discovery Guidelines “are not officially part of the Maryland Rules and have not been adopted or approved by” this Court, we nevertheless arranged to have them reproduced as part of the introduction to Chapter 400 of Title 2 of the Maryland Rules because the “Guidelines, as revised, may be of significant value in interpreting and applying” Chapter 400. Id. “Guideline 9: Objections at *260Depositions” states that “[attorneys objecting to the form of the question at deposition are encouraged, if requested, to state the reason for the objection.” This hortatory language is antithetical to a mandatory statement of grounds that the Court today reads into Rule 2-415(g).
Commentators on the Maryland Rules, as they relate to depositions, have not alerted practitioners to any necessity for stating the grounds of those objections that are required to be made at a deposition in order to avoid waiver. See P.V. Niemeyer & L.M. Schuett, Maryland Rules Commentary, Rule 2-415, at 281-82 (2d ed.1992); P.W. Grimm, Taking and Defending Depositions, A Handbook for Maryland Lawyers § 5.4, at 46-47 (1991).
The majority opinion takes the position that references in Doggett v. Tatham, 116 Md. 147, 151, 81 A. 376, 378 (1911), Brown v. Hardcastle, 63 Md. 484, 495 (1885), and Kerby v. Kerby, 57 Md. 345, 361 (1882), to stating at a deposition the ground for objection are to be read into Maryland Rule 2-415(g), because those cases have not been overruled. Any such requirement, however, was eroded, in my opinion, by rules adopted by this Court on November 1, 1945. Md.Code (1939,1947 Cum.Supp.), Appendix B. Rule 10(c)(1) of the rules relating to depositions of the General Rules of Practice and Procedure presented the substance of the last sentence of present Rule 2-415(g), while deposition Rule 8(a) of the then rules provided for oral examination of deponents to proceed as permitted at the trial. Id. at 2032, 2034. At the same time Rule 17 of the Rules of the Court of Appeals was added. In connection with preserving the record for appeal it provided •that, “[ujnless requested by the court, it is not necessary to state the grounds for objections to evidence except in circumstances in which it would heretofore have been necessary to call attention to special grounds for objection.” Id. at 1995.
In 1956, this provision in Rule 17 was moved to Rule 522 d 1 of the newly adopted Maryland Rules of Procedure, which provided, “[ujnless requested by the court, it is not necessary to state the grounds for objections to evidence.” Md.Code *261(1957) (adopted July 18,1956; effective January 1,1957). The Committee Note following Rule 522 explains the change from former Rule 17:
“The Committee eliminated the following words, following the word ‘evidence’ in subsection d 1: ‘... except in circumstances in which it would heretofore have been necessary to call attention to special grounds for objection.’ This was the last part of the next to last sentence of Court of Appeals Rule 17.”
In 1984, Rule 522 d 1 was incorporated into newly adopted Rule 2-517(a). Md. Rule 2-517(a) (1984 RepLVol.).
An additional complication in the majority’s opinion arises from its repeated references to the City’s objections as going to the form of the questions, as if the issue concerned the second sentence of Rule 2-415(g). Assuming that an objection to the form of a question may lie for some reason other than the question’s leading nature, a question that seeks to elicit a medical opinion, without stating the standard of reasonable medical certainty (or probability) does not, in my opinion, present a defect of form.
The source of the problem is Davis v. Goodman, 117 Md.App. 378, 700 A.2d 798 (1997). In Davis, the Court of Special Appeals summarily concluded, based on an opinion of the Missouri Court of Appeals, that the above-described type of objection went to the form of the question. “An objection that questions put to an expert at deposition were not framed in terms of ‘reasonable medical certainty’ has been held to be an objection to form. See Turnbo by Capra v. City of St. Charles, 932 S.W.2d 851, 856 (Mo.App.1996).” 117 Md.App. at 397 n. 4, 700 A.2d at 807 n. 4. The Davis court did not cite any Maryland law, nor any other state or federal law, to support this statement.
In general, under Maryland law, expert medical witnesses are not required to render their opinions with the talismanic words “reasonable medical certainty” or “reasonable medical probability” in order for the opinion to be admissible. However, where expert opinion testimony is used to establish, for *262example, proof of causation or damages, such evidence must be sufficiently probable and not be based on speculation or conjecture. Pierce v. Johns-Manville Sales Corp., 296 Md. 656, 666, 464 A.2d 1020, 1026 (1983); Kujawa v. Baltimore Transit Co., 224 Md. 195, 203-04, 167 A.2d 96, 99 (1961); Ager v. Baltimore Transit Co., 213 Md. 414, 420-21, 132 A.2d 469, 472-73 (1957).
An expert who states the opinion with “reasonable medical certainty” or “reasonable medical probability” is, in effect, stating the degree of conviction with which the opinion is held. “This standard of ‘reasonable’ medical certainty, reflects an objectively well founded conviction that the likelihood of one cause is greater than any other; it does not mean the expert is ‘personally certain’ of the cause, or that the cause is discernable to a certainty.” Clifford v. United States, 532 A.2d 628, 640 n. 10 (D.C.1987) (citation omitted).
An expert opinion that is not rendered with reasonable certainty or reasonable probability is not necessarily inadmissible. For example, the opinion may be admissible when, in conjunction with additional evidence, the combination amounts to sufficient probable proof of causation. Charlton Bros. Transp. Co. v. Garrettson, 188 Md. 85, 94, 51 A.2d 642, 646 (1947) (“The law requires proof of probable, not merely possible, facts, including causal relations. Reasoning post hoc, propter hoc is a recognized logical fallacy, a non sequitur. But sequence of events, plus proof of possible causal relation, may amount to proof of probable causal relation, in the absence of evidence of any other equally probable cause.”).
Thus, a question that asks a medical witness for an expert opinion, without asking for the opinion to be stated with “reasonable medical certainty” or “reasonable medical probability,” is not a question improper in its form and insufficient to elicit the expert opinion. Rather, such a question asks for an expert opinion that might not be stated with the requisite certainty or probability to be admissible, standing alone. Admissibility is a determination that is made by the trial court, Md. Rule 5-104(a). Consequently, by using the facts of this *263case to require a statement of grounds, the Court has moved beyond the easily recognized leading question and, in effect, is applying the exception to the general rule in the last sentence of Rule 2-415(g) to a matter of substance. That raises a far-reaching policy question.
The policy reasons advanced in the majority opinion are fairly debatable, but I do not believe that we should engraft this new requirement on Rule 2-415(g) without having the Rules Committee expressly consider it, and without giving any opportunity to the Bar to comment on any such requirement. One of the persistent problems in deposition practice is the attorney who sets out to obstruct the deposition by interjecting repeated objections. The ultimate resort to control the obstructionist attorney, unfortunately, is an application for sanctions. Obtaining sanctions is difficult enough when the obstructionist attorney can attempt to justify the conduct complained of by pointing to the vagueness of the requirement that objections be made in order to avoid waiver where “the ground of the objection is one that might have been obviated or removed if presented at that time.” The downside of the Court’s new requirement is that it gives the obstructionist attorney even more ammunition, and more protection against sanctions, by requiring that grounds be stated. The path down which the Court today steers deposition practice also impacts the conscientious attorney. I can foresee attorneys, fearful that the rule of von Lusch v. State, 279 Md. 255, 268, 368 A.2d 468, 472-73 (1977), will be applied to the statement of grounds, advancing at the deposition every conceivable ground of objection that might be considered as one that might be obviated or removed at the deposition.
Finally, I am concerned that the majority opinion weakens the adversarial system. Under my interpretation of the requirements of Rule 2-415(g), the objecting attorney need only object, and the examining attorney has the choice of moving on or backfilling to correct any perceived deficiency. Given the elusiveness of the standard, “unless the ground of the objection is one that might have been obviated or removed if presented at that time,” we should not impose on objecting *264counsel the added burden of educating examining counsel on deficiencies in the testimony that has been elicited. Objecting counsel has a duty to object to then curable deficiencies in the examination, examining counsel has a duty to conduct the examination in a proper manner, particularly when the deposition testimony is to be used in lieu of live testimony at trial, and the court has a duty to rule on the objections, the grounds of which are stated when the parties are before the court.
In those instances in which objecting counsel chooses to state the ground for the objection in order to be cooperative, counsel undoubtedly does so because counsel has concluded that there is no detriment to the client. But objecting counsel should not be forced to assist opposing counsel in preparing the adversary’s case, where objecting counsel concludes that the client’s legitimate interests require that the deposition proceed in literal compliance with the Rule.
In the instant matter the difference between the majority’s analysis and my analysis does not alter the result. The problem was cured when the deponent testified that all of the opinions that he had expressed were held to a reasonable degree of medical probability.
Chief Judge BELL has authorized me to state that he joins in the views expressed herein.