PARTRICK FIGHTING DISCOVERY
(Lucy, you got some splaining to do...on peer review)
(Lucy, you got some splaining to do...on peer review)
(avatar above created from actual audio of Sean Partrick stating that potential witnesses were protected from testifying under a peer review privilege. However, NO witness ever attended a peer review committee...)
INTERROGATORY NO. 35: Identify, with specificity, what evidence you received that lead you to believe that The Laurels of Forest Glenn had employees covered by peer-review protections.
Pay particular Attention to Partrick's statement when he says who he is representing (Oak Health Care), but he stated in the motions to quash the subpoenas of the witnesses that he represented them. The discovery question below seeks to ascertain if he knowingly violated the rules of professional conduct or simply did so negligently.
INTERROGARTORY NO. 12: Explain in detail, why you and the lawyers in your firm failed to obtain informed consent, confirmed in writing from neither the affected client nor the prospective client, prior to your representation of subpoenaed witnesses who were employees of The Laurels and who had interests materially adverse to those of your clients, The Laurels and Oak Health Care Investors and why you failed to give prompt written notice to the prospective clients concerning conflict of interests.
Pay particular Attention to Partrick's statement when he says who he is representing (Oak Health Care), but he stated in the motions to quash the subpoenas of the witnesses that he represented them. The discovery question below seeks to ascertain if he knowingly violated the rules of professional conduct or simply did so negligently.
INTERROGARTORY NO. 12: Explain in detail, why you and the lawyers in your firm failed to obtain informed consent, confirmed in writing from neither the affected client nor the prospective client, prior to your representation of subpoenaed witnesses who were employees of The Laurels and who had interests materially adverse to those of your clients, The Laurels and Oak Health Care Investors and why you failed to give prompt written notice to the prospective clients concerning conflict of interests.
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