A Jasper County couple has filed a petition to perpetuate testimony from Christus St. Elizabeth Hospital in anticipation of a possible lawsuit alleging the man had an allergic reaction to medicine he was given while at the hospital.

Burl A. and Erin Corkran claim Burl was a patient at Christus St. Elizabeth Hospital in Beaumont on Feb. 26, 2007, when he was given the injection, according to a complaint filed Nov. 10 in Jefferson County District Court.

In order to establish the burden of proof, Burl claims he needs his past medical records and an expert in the field at a hearing.

"Petitioners move the court to allow the oral deposition examination of the custodian of medical records for Christus Health, dba Christus St. Elizabeth Hospital, by duces tecum, regarding the circumstances surrounding the injuries to Burl A. Corkran," the petition states.

"From Petitioners' counsel's past experience, that suit will involve expert testimony as to the cause of the injury," the suit states. "Such testimony must be based upon facts reasonably relied upon by experts in the particular field upon which evidence is sought."

The Corkrans are requesting that the court order the oral deposition of the medical records and for other relief the court determines appropriate.

Paul F. Ferguson, Jr., of Provost Umphrey Law Firm in Beaumont will be representing them.

The case has been assigned to Judge Milton Shuffield of the 136th District Court.

Case No. D182-689

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