Zane v. Friends Hospital

Order denying plaintiff's motion for sanctions against defendant for failure to comply with a discovery order was vacated because, in denying plaintiff's motion, the judge violated the coordinate jurisdiction rule by failing to enforce another judge's previously- entered order.

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� 1 Appellant filed a negligence suit against Friends Hospital (“Friends”), Ronald Anderson and Dr. John Doe following injuries she suffered when she was physically and sexually assaulted by Anderson, a patient of Friends’, while she was an outpatient of Friends’.

� 2 During the pre-trial phase of the suit, Appellant requested from Friends records related to Anderson’s hospitalization. Judge Albert Sheppard of the Court of Common Pleas of Philadelphia County entered an order on April 25, 1997, ordering production of certain related documents and information. Upon a challenge to the discoverability of that information, Judge Sheppard entered another order on May 6, 1997, which provided:

… Friends Hospital shall produce for in camera inspection all documentation concerning only the history given to Friends Hospital by Ronald E. Anderson, including his social security number and date of birth.

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Zane v. Friends Hospital

Order denying plaintiff's motion for sanctions against defendant for failure to comply with a discovery order was vacated because, in denying plaintiff's motion, the judge violated the coordinate jurisdiction rule by failing to enforce another judge's previously- entered order.

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