What could be easier? You want medical records? Just send out a request for production to plaintiff’s counsel and you’re done, right? Most likely not – unless you are confident that plaintiff’s counsel will take care to diligently identify, locate and disclose every potentially relevant medical record, as early in the litigation as possible – all from the defendant’s perspective. Without assigning blame, we can at least say that discovery in personal injury litigation “just does not work that way.” Useful and efficient discovery of medical records is not difficult, but does necessitate planning by the defense. What follows is one such plan: ten steps defense counsel can take to timely obtain helpful medical records with minimal conflict. To read the article, click here.