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Scenario Mrs. White was admitted to Richmond Medical Center (RMC) for hip replacement surgery. Preoperatively, she was administered a prophylactic medication to reduce postoperative gastrointestinal

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Scenario Mrs. White was admitted to Richmond Medical Center (RMC) for hip replacement surgery. Preoperatively, she was administered a prophylactic medication to reduce postoperative gastrointestinal complications as part of surgeon Dr. Gilshrist's standing orders. Unfortunately, Mrs. White had an allergy to the drug listed in her medical record, but it went unnoticed by the staff. Once the error was recognized, diphenhydramine was given to counteract the original medication, but that caused a steep drop in her blood pressure, which led to a stroke. Mrs. White suffered dysphasia and hemiplegia, which continue to this day. Mrs. White sued Dr. Gilshrist and the nursing staff for damages due to her injuries. Her attorney, Ms. LeClair, recognized the need to move quickly to preserve the documentation related to the case. Next, knowing that RMC's medical records were hybrid, Ms. LeClair needed access to the electronic documents in her patient's record and any emails that may be pertinent to the case. Documents were then exchanged among the various lawyers and hospital staff members who gave pretrial oral testimony. Upon reviewing hospital documents, Ms. LeClair's team found a metadata discrepancy on an e-form used to document the patient's vital signs. The attorney requested that the court issue an order for the nurse responsible for the documentation to appear at the trial. Based on the nurse's statement at trial that the document had been altered to reflect constant vital sign monitoring with no substantial change, the deciders of fact supported Mrs. White and awarded 4.3 million dollars in damages. Based on that necessity, the attorney's first step should be to ask the court for what? Explain why that is a necessary step in this proceeding

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