Grafilo v. SooraniAnnotate this Case
The Court of Appeal affirmed the trial court's order compelling the production of defendant's patients' medical records to the Medical Board of California. The court held that, when the Board seeks psychiatric records, it must demonstrate a compelling interest to overcome a patient's right to privacy, and the Board made a sufficient factual showing of good cause to compel compliance with the subpoenas. In this case, the Board established the absence of less intrusive alternatives, the trial court did not abuse its discretion by admitting and relying on the declaration of the Board's medical consultant; and the consultant's declaration provided the trial court with sufficient competent evidence of good cause. Finally, the court denied defendant's motion for judicial notice of printouts of webpages from the Prescribers' Digital Reference and the Mayo Clinic website, which provide drug summaries for clonazepam.