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Zuniga & Pierce, separately, refused Federal subpoenas duces tecum for
investigation of Medicaid/Blue Cross fraud. subpoena's asked for names, dates, services to
compare to records. Cases heard together, Court said these data did not fall in dr-patient
privilege, this request did not violate right to privacy, 5th Amendment didn't count here
because they were professional corporations, not individuals. Federal Court doesn't have
any blanket privilege for Dr.
cf Commonwealth v Kobrin