By Order on Motion to Quash Subpoena Duces Tecum entered March 13, 2020, Chesterfield Circuit Court granted the third-party hospital’s motion to quash the personal injury Defendant’s subpoena for medical costs paid by its non-party patients for procedures similar to that of Plaintiff, finding the subpoena overly broad and unduly burdensome. Obviously the subpoena was a naked attempt to attack Virginia’s time-worn collateral source rule. The vehicle accident case is Powell v. Honn, No. CL19000325-00.
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