Medical malpractice plaintiffs are entitled to discovery of a physician’s hospital personnel records generated in the ordinary course of employment and so are not protected as peer review material, a Philadelphia Common Pleas Court has ruled in a memorandum opinion.

Documents do not fall within the Peer Review Protection Act exception as non-discoverable unless “prepared solely for the purpose of peer review and used only for peer review …” wrote Judge Mark I. Bernstein in Pitts v. The Children’s Hospital of Philadelphia.