Gutierrez-Zacatenco v. Herrera

Summary

The court held that medical records obtained from an opposing party in discovery may be authenticated under the general authentication provision rather than exclusively through the subpoena procedure for custodians of medical records. The incomplete records were sufficiently authenticated, and the failure to specifically identify them in pretrial disclosures was harmless because the opposing party had advance notice of their intended use. The court also held that medical-lien evidence may be relevant to show treating physicians' bias and ordered a new trial; the attorney-fee and cost award was vacated and the post-judgment relief appeal was rendered moot.