Dominguez v. Omana, M.D.
In a medical malpractice case, the trial court overruled the plaintiff's objections to non-party subpoenas seeking 'any and all' medical records for the prior ten years and refused an in-camera inspection. The Sixth DCA granted certiorari and quashed, holding that although the plaintiff waived privacy in relevant records by suing, the subpoenas cast too wide a net and the trial court was required to either narrow their scope or conduct an in-camera review.
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