BEASLEY, Judge.
Black filed a petition under OCGA § 9-11-27(a) to perpetuate the testimony of Paugh, the chief executive officer of St. Joseph Hospital, prior to the filing of a complaint. She anticipated filing a medical malpractice suit against Dr. Owen, who had performed surgery on her, and against St. Joseph Hospital for negligently granting Owen staff privileges. Black contended Paugh had documentary information concerning hospital policies and the decision...
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