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Motion to Compel, Maryland
Kevin Barkman v. Fahrney-Keedy Memorial Home, Law C-21-CV-18-643
By Jeffrey J. Downey
Serving clients in Virginia, Maryland and the District of Columbia.
Address: 8270 Greensboro Drive, Suite 810, McLean, VA, 22101
Phone 703-564-7318. On the web at www.jeffdowney.com.
The attached order was entered in the above case on April 2, 2019. The underlying complaint alleged negligence leading to multiple falls and Mr. Barkman’s death on May 14, 2016.
To support the allegations in this case, Plaintiff filed the underling Motion to Compel. I am including relevant attachments here. Also attached is my Reply Memorandum.
Attorneys downloading this information should update their research before filing any discovery Motions. There are very few published discovery decisions involving medical malpractice in Maryland State Courts. The discovery order in Barkman and the discovery decisions in Ratti v Charles County Nursing and Rehabilitation Case No C08-1511 (Charles County Circuit Ct. 2009)(Exh. No. 6 to underling Motion) represent the only nursing home discovery decisions I could find in Maryland. In Ratti, the Court ordered the nursing home to produce, inter alia, personnel files of the nurse(s) and nurse aid(s) who cared for the Plaintiff, under a protective order.
Attorneys litigating cases in Maryland should not hesitate to file discovery Motions in complex nursing home or assisted living cases. The Defendants routinely make incomplete document production in these cases, sometimes failing to identify withheld documents.
If you obtain favorable discovery rulings in a Maryland malpractice case, please send me copies, so I can include them on this website.
Thank you for your interest,
Jeffrey Downey, Esq.
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