Petersen v. Rapid City, Pierre & Eastern Railroad, Inc.

District Court, D. South Dakota·Decided March 6, 2024·No. 5:22-cv-05064·Unknown

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH DAKOTA WESTERN DIVISION

KENNETH W. PETERSEN, JR., 5:22-CV-5064

Plaintiff, MEMORANDUM OPINION AND ORDER DENYING PLAINTIFF’S MOTION FOR VS. SANCTIONS FORGED MEDICAL AUTHORIZATION RAPID CITY, PIERRE & EASTERN R.R., INC.

Defendant.

On December 4, 2023, this Court issued an order with regard to Plaintiff Kenneth Petersen’s Motion for Sanctions Forged Medical Authorization. It was undisputed by the parties that Plaintiff’s medical authorization had been altered without Plaintiffs permission, but it was disputed by the parties as to who altered it. The Court noted that it had inherent authority to impose sanctions upon attorneys for unethical or bad faith conduct. The Court ordered that Plaintiff's counsel may take the deposition of Gillian Grunkemeyer, paralegal from the Boulder, Colorado office of the Knight, Nicastro McKay law firm and report back to the Court because she was the individual who had faxed Plaintiff’s medical authorization form that is at the heart of this dispute to Black Hills Orthopedic & Spine Center on May 16, 2023. Ms. Grunkemeyer’s deposition was taken on January 4, 2024, and the parties reported back to the Court. (See Docs. 127, 129, 133). Having been fully briefed, Plaintiff's Motion for Sanctions Forged Medical Authorization (Doc. 62) is ready for disposition. BACKGROUND During discovery, Defendant Rapid City, Pierre & Eastern Railroad, Inc. (“RCPE”) requested that Plaintiff produce, among other documents, the following:

REQUEST No. 4: All medical records from the last ten years from any hospital, physician, surgeon, chiropractor, therapist, or other health provider.

REQUEST NO. 5: Signed authorizations, including authorizations in compliance with the Health Insurance Portability and Accountability Act (“HIPAA”), to enable defendants to reasonably obtain other discoverable records. (Doc. 64-1). In response to Defendant’s Request No. 4, Plaintiff objected to the over-broad request, asserting that the information sought fell outside the scope of discovery as defined under Fed. R. Civ. P. 26(b)(1), that the information sought was not proportional to the needs of the case, including the burden and expense of the proposed discovery relative to its likely benefits, and that the information sought was privileged medical information not put at issue by Plaintiff in the litigation. (Doc. 64-2). In response to Request No. 5, Plaintiff objected to the “overly broad” request, asserting the same objections as were in response to Request No. 4. (Doc. 64-2). Tn turn, Plaintiff produced his own medical records release authorization to Defendant (Doc. 64-3). Of the seven authorizations for release provided on March 7, 2023, to RCPE’s attorneys at Knight Nicastro MacKay, was one for Black Hills Orthopedic & Spine Center. (Doc. 64-3). The Black Hills Orthopedic & Spine Center authorization contained, among other information: the name of the medical provider, a statement that the information in the release was needed for the purpose of litigation, the specific type of medical information to be disclosed, a statement that only an original copy of the release authorization was valid, and Petersen’s original signature. (Doc. 64-3). Of the 19 types of information, Plaintiff clearly marked “NO” next to three: Drug/Alcohol Abuse, HIV/AIDS, and All Records: _ x History & Physical x Discharge Summary x Operative Notes x Consultation x Lab x ___ Emergency Room Report x Progress Notes x Social History ‘x Counselor's Discharge Summary x Radiology Reports/Films x Psychological Testing x Physical Therapy Drug/Alcohol Abuse x Mental Issues NO_ All Records NO HIV/AIDS x Correspondence x Billing Records (Doc. 64-3). On March 14, 2023, RCPE attorneys faxed Black Hills Orthopedic & Spine Center a cover letter bearing the name of Rachel Ford, paralegal of Knight Nicastro MacKay in Peoria, Illinois,

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and Plaintiff’s authorization form. (Doc. 90-6). The cover letter provided that “Pursuant to the enclosed executed HIPAA release, please forward copies of any and all medical records, including any radiology film and or imaging (x-rays, MRIs, CT scans, etc.), and medical bills in accordance with the authorization.”) (Doc. 90-6). Although it is not clear from the record the exact date of her departure, Ms. Ford left defense counsel’s firm, and Ms. Grunkemeyer, a paralegal with Knight Nicastro McKay in Boulder, Colorado, became involved “in the process of following up on previous record requests.” (Doc. 128-1, Grunkemeyer Dep. 16:14-19:10). On May 15, 2023, Gillian Grunkemeyer called Black Hills Orthopedic & Spine Center to confirm that the clinic had received the first authorization request faxed previously by Ms. Ford and was informed that the authorization had been received and rejected by a records-handling service called Sharecare. (Doc. 128-1, Grunkemeyer Dep. 21:19:23:5). During the phone call, Ms. Grunkemeyer was informed that the request had been rejected by Sharecare because: “1) The ‘All Records’ filed is marked ‘No’ [and] 2) They want it to specifically say “All dates of service.” (Doc. 128-1, Grunkemeyer Dep. 23:1-11). That same day, on May 15, 2023, counsel for RCPE informed Plaintiff’s counsel via email that the authorization had been rejected because: 1) the “All Records” box was marked “No” and 2) they want it to specifically say “All dates of service.” (Doc. 90-7). Defense counsel requested that a new provider-specific release be executed and returned. (Doc. 90-7).

Inaconversation with Sharecare (whose contact information she obtained from Black Hills Orthopedic & Spine), Ms. Grunkemeyer learned that Sharecare was sending emails to Ms. Ford, the paralegal who had faxed the original records request to Black Hills Orthopedic & Spine Center on March 14, 2023. (Doc. 128-1, Grunkemeyer Dep. at 24:4-12). Ms. Grunkemeyer testified that on May 16, 2023, at 4:24 p.m., she faxed to Black Hills Orthopedic & Spine Center an updated cover letter and Petersen’s authorization form in order to try and clear up Sharecare’s objections to the authorization form sent by Ms. Ford on March 14th and so that she would receive all future correspondence. (Docs. 128-1, Grunkemeyer Dep. 24:4-12; 64-5). Grunkemeyer testified that she attempted to address the date-of-service issued by “direct[ing] them to the paragraph on [Petersen’s] authorization where it indicates that all dates of service are authorized.” (Doc. 128-1, Grunkemeyer Dep. 27:15-25). Ms. Grunkemeyer stated that she attempted to address the “ ‘no’ to all records” issue in her cover letter by, “list[ing] out per the authorization each item that was

authorized as being what we were requesting.” (Doc. 128-1, Grunkemeyer Dep. 28:1-11). Specifically, the updated cover letter provided in relevant part that: Pursuant to the authorization, we would ask that your office provide to us an (sic) electronic copies or photocopies of any and all records in your files including, but not limited to: History & Physical, Consultation, . Progress Notes, Radiology Reports/Films, Billing Records, Discharge Summary, Lab, Social History, Psychological testing, Mental issues, correspondence, operative notes, Emergency Room Report, Counselor’s Discharge Summary, Dismissal Instructions, and Physical Therapy. (Doc. 64-5). On page 2 of the fax was Plaintiff’s executed authorization form. (Doc. 64-5). Grunkemeyer did not hear anything from Sharecare after sending the authorization on May 16, 2023. (Doc. 128-1, Grunkemeyer Dep. 28:12-18). Around May 30, 2023, Ms. Grunkemeyer received a message from Sharecare that the records requested in the authorization were ready for download. (Doc. 128-1, Grunkemeyer Dep. 28:12-29:19). Grunkemeyer did not speak with Sharecare or Black Hills Orthopedic & Spine Cener between those two dates. (Doc.

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