1. Health Plan is the respondent not Doctors (refused to give resumes, field license, work schedules, sign contract w/ deceased) stated client privileges, trade secret as health plan only provide medical/hospital service thru contracts with other HMO hospital and Medical Doctor Group, so all of those above requests were called "Speculation" "Irrevelance" "Oppression" "to the case.
2. Stated treated Doctors are not proper Parties for this arbitration to avoid all Malpractice responsibility
3. Caught them lie on Refused to produce as they stated Request info already in the possession of Claimant -untrue, cant access Doctors' resume.
4. Stated violated the Code of Civil 2031.030(c)(1) request on their business record.
5. Stated violated the Evidence Code 1157 & CCP 2034 on Medical WitnessesAll above sounded very bogus to us as it was part of the standard lawsuit request per my Law Professor. I am rephrased the Discovery's questions to see if they still respond to the same thing or not but the same time, I would plan to file a motion of compel on advices earlier at this message board but (A) need to find out how to able to go around to get Doctors' resumes, work schedule, etc as HMO already claimed Drs are not part of this Arbitration. Can I request a subpoena the other entities to collect the inquiry info and record? This is an arbitration so request would be send to the retired Judge? (B) As they refused to produce their Star Medical Witnesses for us to interrogate for this arbitration, can they bring in later? (C) Can we take depo to those Drs (who treated the Deceased) even the HMO lawyers stressed Drs are not part of the lawsuit complaint? How to get around? My former attorneys had put those Drs in the initial complaint (unless they screwed us up after took $$$ & ran). Pls advise.