8 So. 3d 1268 (Fla. 2d DCA 2009)
A hospital filed a Petition for Writ of Certiorari, arguing that Amendment 7 (the “Patients’ Right to Know” Amendment) violated the common law work product doctrine. The Firm successfully argued that Amendment 7 preempted the common law work product doctrine as it applied to existing reports of adverse medical incidents. The Opinion certified a question to the Supreme Court of Florida, though the Court declined to exercise jurisdiction. See Lakeland Reg’l Med. Ctr. v. Neely, 12 So. 3d 752 (Fla. 2009).