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Freeman v. Lincoln Beach Motel

Citations: 442 A.2d 650; 182 N.J. Super. 483

Court: New Jersey Superior Court; November 19, 1981; New Jersey; State Appellate Court

Narrative Opinion Summary

In this case, the plaintiffs, Allen M. Freeman and Olga Freeman, were required to sign authorizations for the release of medical records after a personal injury claim was filed regarding injuries Allen Freeman sustained at the Lincoln Beach Motel. The defendants sought access to these records to support their defense, invoking New Jersey Court Rules R. 4:10-1 and R. 4:10-2, which permit broad discovery of relevant and non-privileged matters. Additionally, N.J.S.A. 2A:82-41 was cited to ensure the defendants' right to examine the medical records directly from the providers. The plaintiffs opposed this, claiming it breached the attorney-client relationship and that New Jersey law did not require them to comply with such requests. The court dismissed these objections, emphasizing the necessity of transparency and full disclosure in personal injury litigation. The court's ruling mandated that the plaintiffs either provide the medical records or sign the requested authorizations, provided the request distinctly specified the hospital and dates. This decision underscores the principle that parties seeking damages for personal injuries must allow comprehensive examination of pertinent records to ensure fairness in the adjudication process.

Legal Issues Addressed

Discovery Rules under New Jersey Court Rules

Application: The court applied New Jersey Court Rules R. 4:10-1 and R. 4:10-2 to allow the defendants access to relevant non-privileged medical records of the plaintiffs.

Reasoning: The court referenced New Jersey Court Rules R. 4:10-1 and R. 4:10-2, which allow broad discovery of non-privileged, relevant matters...

Examination of Medical Records under N.J.S.A. 2A:82-41

Application: The statute was utilized to mandate the disclosure of medical records directly to defendants without requiring mediation by the plaintiffs’ attorney.

Reasoning: ...N.J.S.A. 2A:82-41, which permits examination of medical records by defendants in personal injury claims. The statute aims to ensure full disclosure...

Obligation to Sign Authorizations for Discovery

Application: The court required the plaintiffs to sign authorizations for the release of medical records when such records are under their control, supporting comprehensive discovery.

Reasoning: The court ordered the plaintiffs to either produce the medical records or sign the authorization, ensuring that the request is specific regarding the hospital and dates involved.