Jessica is the director of Health Information and Technology Services at General Hospital. At this facility, patient records are hybrid. The hospital was named as a defendant in a medical malpractice lawsuit by a former patient (i.e., plaintiff). The trial is scheduled during the next week. During the discovery process, the plaintiff's health records and an incident report relative to the plaintiff's hospital stay were obtained by the plaintiff's attorney. The plaintiff's attorney has made it clear that she intends to have the health records and the incident report admitted into evidence and, further, that metadata associated with the electronic portions of the plaintiffs records will be sought.

1) What is the likelihood of the plaintiff's health records being admitted into evidence? On what legal theory do you rely to support your answer?

2) What is the likelihood of the incident report being admitted into evidence? On what legal theory do you rely to support your answer?

3) What is metadata? What type of information might the plaintiff's attorney be looking for by seeking metadata associated with the electronic portions of the health records?

4) How should Jessica prepare for the trial?