An operator of dialysis clinic argues it should not have to produce hard copies of information about “adverse events” involving its patients because it would require searching records at 2,100 clinics with a client base of 170,000 patients in 2013.

Fresenius Medical Care Holdings Inc., opposing a motion to compel filed in federal multidistrict litigation in Massachusetts, said information about adverse events exists in its corporate data warehouse. The parties have agreed to limit discovery so far to information kept at the corporate level and residing in the corporate data warehouse, Fresenius said.