Demand the audit trail, access log, and metadata in native electronic format — using the exact per-EHR terms. The data that's not in a printed records production: late entries, time-to-document, copy-forward, and who-viewed-the-chart-when.
3 generations/day per IP. Powered by Claude. Grounded in verified per-EHR terminology, HIPAA / ONC, and real case law.
Why this exists: a standard "certified records" production is the chart rendered to PDF — it does not contain the audit-trail metadata. Asking for "the records," or even asking for the wrong report (Epic's Access Log instead of its Audit Trail), yields a useless summary. This tool produces the precise, EHR-specific "magic words" so the request actually reaches the metadata layer.
EHR Audit-Trail Discovery Request
⚠ AI-assisted draft — the attorney must independently verify every citation, statute, court rule, and EHR-specific report name before serving. Do not file or serve without review.