Mr. Moen simply seeks information as to the facts that caused the failure of the intra-aortic balloon, and has informally and unsuccessfully to date, pressed the now-defendant Massachusetts General Hospital to provide it. He claims that he has been stonewalled for quite some time in those efforts, and that his frustration has led to the present lawsuit.

After reviewing the parties' submissions and a hearing, the Court hereby orders the Massachusetts General Hospital to produce the following documents and information to Mr. Moan's counsel within 45 days of the date of this Order:

1. All audit trails or other documents sufficient to identify each person who accessed Mr. Moan's medical records from October 2, 2014 to the present date; when they accessed it; during and for what periods of time they accessed it; what they accessed; and all changes or additions made to Mr. Moan's medical records by each such person at each time each such person accessed it.[1] In addition to paper form, the Massachusetts General Hospital shall produce this information in electronic form, with adequate instructions as to how to access it;

2. The Massachusetts General Hospital shall identify and produce a Rule 30(b)(6) deponent and/or any other person capable of accessing Mr. Moan's medical record during a deposition and determine the information contained in the above-numbered first paragraph to be deposed at Mr. Moan's counsel's discretion;

3. The Massachusetts General Hospital shall identify the name and corporate address of the company that sells, hosts and/or services its electronic medical records system so that the company's Rule 30(b)(6) designee and any other person may be deposed in accordance with the above-numbered paragraphs numbered 1 and 2;

4. The Massachusetts General Hospital shall identify the person most knowledgeable regarding the preservation and/or destruction of the intra-aortic balloon involved in the incident on October 3, 2014, to be deposed at the plaintiff counsel's discretion;

5. The Massachusetts General Hospital shall produce all documents and correspondence, including emails, by and between any physician, staff, or employee of the Massachusetts General Hospital, or any other person or entity, regarding Jeffrey Moan and/or the incident involving Jeffrey Moan on October 3, 2014 and/or the events that led to the loss of his leg;

6. To the extent that the Massachusetts General Hospital claims any documents responsive to the above-numbered paragraph 5 are privileged, it shall provide, within the forty-five day period set forth in this Order, a privilege log conforming in all respects to Mass. R. Civ. P. 26(b)(5) and Superior Court Rule 30(A)(3)(b);

*2 7. The Massachusetts General Hospital shall identify the person most knowledgeable regarding the search for the documents and information sought in this Order, to be deposed at plaintiff counsel's discretion, with the exception of any person who served on a Peer Review Committee or who conducted any investigation on behalf of the Peer Review Committee.

8. The Court shall hold a status conference to determine the Massachusetts General Hospital's compliance with this Order on Thursday, June 9, 2016 at 2 pm, and at that time the parties shall submit a schedule for depositions to take place with 120 days thereafter. The parties shall confer and attempt to agree—to the extent possible—on the deposition schedule before the status conference.

The Massachusetts General Hospital need not supply the names of the eleven individuals who composed the Peer Review Committee or those individuals who investigated Mr. Moan's medical incident on behalf of that Committee.