See below for a sample of a lawyer's letter requesting for medical information.
Messrs Perry Mason Tan & Partners
12 St Andrew's Road
Singapore 12345
Telephone 1234565
Fax 1234555Advocates & Solicitors
______________________________________________________________________________Reference: WW1232/56
12 April 2001
Dr Harold Robin Lim
HRL Clinic for Women
34 Mt Senai Road
Singapore 12345Dear Sir
Request for medical report Madam Hua Moo Lan
We act for Madam Hua Moo Lan
We are instructed that our client was your patient and you had diagnosed her as having endometronic cyst of left ovary and adenomuosis uteric. On 23 October 1999, she underwent surgery to remove the left ovary and uterus. Following the surgery, our client had suffered and complained of abdominal pain, swelling and fever. On 5 November 1999, Dr Whampoa Tan attended to her. A CT scan revealed the possibility of injury to the right ureter as indicated by a collection of fluid on the right side of the abdomen and pelvis. After discussions between you and Dr Whampoa Tan, our client was referred to Dr Bendemeer Lim, a Consultant urologist.
On 7 November 1999, our client underwent surgery for a right nephrostomy tube insertion. A right lower ureteric obstruction with hydronephrosis and extravasation of the urine was noted. She underwent nephrostomy tube drainage for six days. After the surgery, our client continued to experience pain at the right loin. On 12 November 1999, she underwent exploration of the right lower ureter by Dr Whampoa Tan. The finding was obstruction of the right lower ureter with extrinsic constriction of the ureter. The ureter was congested, oedematous and adherent with dilatation due to previous extravasation. The right ureter was re-implanted to the bladder. Following the surgery, she required a right nephrostomy tube insertion to drain the right kidney due to oedema of anatomosis following surgery.
Our client has suffered pain and distress and incurred additional medical and other expenses. On 21 December 1999, our client made a complaint to Singapore Medical Council (SMC). By a letter dated 19 March 2000 , SMC stated that it had carefully considered your explanation and the opinion of a senior gynaecologist and found no evidence of professional misconduct or negligence by you. Our client is dissatisfied with the decision of SMC.
On the facts disclosed above, there may be reasonable grounds to claim for breach of contract or for negligence in relation to the operation on 23 October 1999 and the care/medical treatment received by her after the operation. As such, our client would like to obtain full details of the operation carried out by you on 23 October 1999 including all relevant medical/operation reports and case notes to enable our client to decide whether there had been a breach of contract or negligence. If there is such a claim, you are likely to be a party to the proceedings.
Please be informed that the law (The changes introduced by the Supreme Court of Judicature (Amendment) Act 1993 and the rules passed pursuant thereto) and the circumstances of this case entitles our client to request for full particulars and ask questions in respect of the said operation. The purpose is to make available material documents and information to enable a prospective claimant to assess the merits of a claim before legal action is launched. In the event that such a request is not complied with, our client shall be compelled to apply to the court to seek an appropriate order.
Please let us have a reply within seven days hereof. Our client shall pay reasonable costs for the documents and information requested for by this letter.
Yours faithfully,
Perry Mason Tan & Partners
Raffleslaw.com