Q: Demand for disclosure by hospital of affiliation of provider

A: Under California law, a party can request information about the affiliation of a healthcare provider with a hospital during the discovery process. This is typically done through a request for production of documents or interrogatories. To ensure the authenticity of the information provided, the request should be phrased in a clear and specific manner.

Here are some key points to consider:

1. Request for Production of Documents: You can request documents that demonstrate the employment or contractual relationship between the healthcare provider and the hospital. This may include employment contracts, service agreements, or other relevant documents.

Example: "Please produce any and all documents that demonstrate the employment or contractual relationship between [healthcare provider's name] and [hospital's name] during the period of [relevant dates]."

2. Interrogatories: You can ask the hospital to provide written answers to specific questions about the healthcare provider's affiliation.

Example: "Please state whether [healthcare provider's name] was employed by or had a contractual relationship with [hospital's name] during the period of [relevant dates]. If so, please describe the nature of the relationship and the dates of the affiliation."

3. Authentication: To ensure the authenticity of the documents produced, you can request that the hospital provide a declaration or affidavit from a custodian of records or other qualified person, attesting to the authenticity of the documents.

Example: "Please provide a declaration or affidavit from a custodian of records or other qualified person, attesting to the authenticity of the documents produced in response to [specific request]."

4. Verification: If the hospital provides answers to interrogatories, you can request that the answers be verified under oath by a person with knowledge of the facts.

Example: "Please provide a verification under oath by a person with knowledge of the facts stated in the answers to these interrogatories."

It is important to note that the specific language and requirements may vary depending on the court and the case. It is advisable to consult with an attorney experienced in California discovery procedures to ensure that your requests are properly phrased and comply with applicable rules and regulations.