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Negligence-Personal Injury-Non-Party Subpoena-Financial and Tax Records

Staff Report//May 13, 2026//

Negligence-Personal Injury-Non-Party Subpoena-Financial and Tax Records

Staff Report//May 13, 2026//

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Spine and Joint Centers of Missouri moved for a protective order and to modify the subpoena served by defendants. SCJMO treated plaintiff before he brought the present personal injury action. Defendants requested records and a records custodian deposition from SCJMO. SCJMO argued that it had produced medical and billing records related to plaintiff’s treatment and objected to defendants’ requests for its business tax returns and invoices between it and plaintiff’s counsel.  

Where the requested discovery was not proportional to the needs of the case because it was not relevant to impeach the credibility of plaintiff’s experts and it would be unduly burdensome for SCJMO to produce the requested records, the court granted a protective order.   

Defendant’s motion for a protective order is granted. 

Evans v. Jarvis (MLW No. 84743/Case No. 4:25-cv-00288-SEP – 5 pages) (U.S. District Court, Eastern District of Missouri, Pitklyk, J.) 

 


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