Atkins, supra.Winkles v. Pontiac, No. L-03-1034, 2004 WL 485565, at * 3 (Ohio App. 6 Mar. 12, 2004); see also, Bowins v. Euclid General Hosp. Ass'n, 20 Ohio App.3d 29, 31 (Ohio App. 8 1984) ("[e]xpert testimony is not required unless the subject of inquiry is outside the common, ordinary and general experience of lay persons"). In Brown v. The Raymond Corp., 432 F.3d 640 (6th Cir. 2005), aff'g 318 F.Supp.2d 591 (W.D. Tenn. 2004), the court agreed with the district court's assessment "that a forklift is a complex machine beyond the purview of the ordinary consumer and that Brown was therefore obligated to provide expert testimony in order to survive a motion for summary judgment."