Hyams

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA San Francisco Division RYAN HYAMS, Case No. 18-cv-06271-PJH (LB)

Plaintiff, DISCOVERY ORDER REGARDING (1) PATIENT-SAFETY WORK v. PRODUCT PRIVILEGE AND (2) BURDEN AND CVS HEALTH CORPORATION, et al., PROPORTIONALITY Defendants. Re: ECF No. 99, 115, 126, 129, 130, 132 16 INTRODUCTION The court assumes the reader’s familiarity with the subject matter and procedural history of this case. The parties have raised more discovery disputes, regarding (1) patient-safety work product (“PSWP”) under the Patient Safety and Quality Improvement Act, 42 U.S.C. § 299b-21 et seq. (“PSQIA”),1 and (2) burden and proportionality with respect to the plaintiff’s Interrogatories Nos. 1–4 and 19.2 The court issues this order defining the scope of PSWP protection and directs the defendants to (1) immediately produce all surveillance video and still photographs that they are…