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C.B. v. Sabalos

6/13/2000

DuPage Hosp., 435 N.E.2d 140, 144 (Ill. App. 1982) (non-party patients disclosed information "with an expectation of confidentiality" and whether redaction of their names and identifying numbers from records would protect their identity was "questionable at best").


Conclusion


Because of the likelihood that production of the medical records described in the respondent trial judge's order may lead to identification of the non-party patients, and because the nature of mental health records demands de minimus, if any, encroachment on the statutory protection of the patients' privacy, we find that the respondent's order compelling production of the records was an abuse of his discretion. Therefore, the judge's order of April 4, 2000, is vacated except for the portions denying Roe's Motion to Amend the Complaint and granting the Arizona Center for Disability Law leave to appear in the case.


Relief granted.


PHILIP G. ESPINOSA, Chief Judge


CONCURRING:


J. WILLIAM BRAMMER, JR., Presiding Judge


JOSEPH W. HOWARD, Judge






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