(My wife has a master's degree in health care risk management and deals with this all the time for a large hospital. All requests for discovery including for depositions and documents and admissions land on her desk. If in doubt, she is the one who personally consults with the hospital's law firm.)
I agree. If it's not a written record, you might have to depose the Dr., who will refuse to answer claiming HIPAA or other state law or both, and then you'd have to file a motion to compel and hope for the best.Quote by OP:
If it's not documented, then you have no proof anything was recommended.