Boyd, William

Defendant LeafFilter/Arch Insurance sought removal of an April 30, 2024 Order that limited its subpoenas duces tecum (served on Kaiser, KFH/SCPMG, John Muir Medical Center, and Brentwood Health Center) to medical records pertaining to applicant William Boyd's musculoskeletal system, arising from an admitted July 7, 2022 upper-extremity injury. Defendant argued the limitation violated its discovery rights, forced records clerks to make medical relevance determinations, and left it at an impasse because Kaiser refused to comply with any limited subpoena. The WCAB panel acknowledged defendant's points were well taken but held they failed to demonstrate the significant prejudice or irreparable harm required for removal because defendant had alternative discovery avenues. The panel suggested defendant could notice applicant to appear and produce his complete file under CCP section 198, meet and confer with a privilege log, or move for appointment of a special master to conduct in camera review. The Petition for Removal was denied.