Controlling Medical Records Discovery Costs

[Editor’s note:  In my previous post, I noted that all unfocused and broad-based discovery invariably leads to unnecessary direct legal costs as well as indirect costs.  Because of the importance and complexity of this issue, the next few blog posts will delve into the specific types of discovery that can contribute to unnecessary costs.  First up is the topic of medical records discovery which will be covered by my colleague, Don Douglass. Don is a veteran insurance defense attorney with 30+ years of experience.  John Conlon]

          Controlling Medical Records Acquisition & Review Costs


Donald D. Douglass

There is no question that obtaining and evaluating medical records is an important part of defending a personal injury lawsuit and other litigated cases with medical issues.  However, there is also no question that not all medical records are necessary to have in all cases. And here’s why . . .

[A complete copy of this blog post is available for clients of To obtain a copy, contact]


Unfocused and Overly Broad Form Discovery Leads to Unnecessary and Excessive Legal Costs

The one thing I notice in so many files I review that consistently contributes to excessive and unnecessary legal costs is the use of unfocused and overly broad form discovery.   What I so often see when a new file is assigned to a defense counsel with a request for a discovery or litigation plan is the same time worn (form) plan that has been used in previous cases.

In addition to the overbilling . . .

[A complete copy of this blog post is available to clients of To obtain a copy, please contact]