Stricklin v. Becan

Doctor’s Hospital, Ltd. (hospital), appeals from an order holding it in contempt and imposing a $500 sanction for refusing to turn over a document in discovery to plaintiff which the hospital contends is privileged from disclosure under sections 8 — 2101 and 8 — 2102 of the Medical Studies Act (Act) (735 ILCS 5/8 — 2101, 8 — 2102 (West 1996)). We reverse and remand.

In 1996, plaintiff filed a medical malpractice claim against defendant, Dr. Arthur Becan, over surgery and treatment Becan provided to one of plaintiff’s rotator cuffs in 1994. The hospital was named as a respondent in discovery.…