Bolton v. Holy Spirit Hospital

DOWLING, J.,

We are addressing ourselves to both of the above-captioned cases since they each involve an interpretation of the scope of the Peer Review Protection Act1 as applied to certain discovery problems. We feel that their intertwining may serve to set off the distinctions we are required to make in resolving the issues which, we might add, are complicated by the fact that in neither case has a complaint been filed.

In Bolton v. Sanderson and Holy Spirit Hospital, plaintiffs, husband and wife, are suing defendants for alleged medical malpractice suffered by the wife-plaintiff during a…