Q: What statements have to be included into motion to compel further in order to obtain this information from hosputal?
Why defense can allege that license id and dates of affiliation with hospital is private information?
If it objects to disclose, what are plaintiff's remedies other than subpoena and deposition?
What statements have to be included into motion to compel further in order to obtain this information from hosputal?
A:
To obtain information from a hospital through a motion to compel further responses in California, you need to assert specific legal grounds. First, you must show that the information is directly relevant to the case and that the hospital's objections are not legally valid. Include references to the California Code of Civil Procedure, highlighting the relevance and necessity of the information to your case.
Defense may allege that the license ID and dates of affiliation are private information protected under privacy laws. However, you can argue that these details are critical for verifying the qualifications and credibility of the medical personnel involved, which directly impacts the case's outcome.
If the hospital refuses to disclose this information, your remedies, aside from subpoenas and depositions, include filing a motion to compel further responses. You can also request sanctions against the hospital for failing to comply with discovery obligations. Ensure your motion to compel is detailed, demonstrating that you have attempted to resolve the issue informally before seeking court intervention.
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