Defendants often attempt to hide information by filing motions to prevent Plainitffs from interviewing former employees about facts material to Plaintiffs' claims of neglect and understaffing. We have uploaded a couple of Orders here and here allowing contact between former employees and Plainitffs. The Order discusses in detail the Rules of Professional Conduct 4.2.
We have uploaded a great Order compelling the production of an incident report. The defense attempted to claim that the incident report was work-product. The Court rightly disagreed. All nursing homes are required by state and federal regulations to investigate and prepare incident reports when an incident causing injury to a resident ha occurred. This is done in the ordinary course of business and not as result of anticipation of litigation. These incident report should be produced but defense attempts to hide these incident reports from the families of residents.
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