In re Methodist Hospital:
a)    Family sued hospital b/c negligent in surgery which caused infection and required further surgery.
b)    Request for documents in relation to any reports of infectious diseases reported.  Request denied for confidentiality.
c)    There are two types of records–that collected in course of business, that which is generated by committee for purposes of quality of care.  An infectious disease report is generated for quality of care but does not analyze a specific past activity.
d)    The court held that the documents were made or maintained in the course of business and were discoverable.  The report was administratively separate from committee evaluations.